European Aerosols GROUP - CODE OF CONDUCT


Principles for responsible and legal conduct within the European Aerosols GROUP

Our company operates worldwide – and laws, codes of conduct or customs are as diverse as the mentalities and languages of our workforce. Our joint success is based on the trust of our customers and staff. Therefore we set standards with regard to responsibility – both for our company and also each and every individual.

The Code of Conduct of the European Aerosols Group shall document these binding standards and provide a guideline which can be applied by everyone in all relevant countries. It shall help implement our company’s values in everyday working life.
It shall make it clear what is expected from the staff of the European Aerosols Group. It shall show how to deal with potential questions or difficult situations regarding our business practices or the way we deal with each other.

 

Preamble

In our present code of Conduct which describes a mode of behaviour as a core and basis of our business culture are our ethical and moral fundamental values depicted.
Honesty, integrity, confiding behaviour, fairness and respect are the essential guidelines of our everyday business. Based on this our customer, partner, employees and colleagues trust in us and our brands.
Everyone who offend against our code of conduct act not loyal. This can damage the prestige of our company and can lead to a serious, economic loss.
Every employee of the European Aerosols Group is requested to act in a responsible way and comply with applicable law according to the code of conduct. Thus every single employee contributes to strengthen the good reputation of our company and helps to reach the targets which also exceed our financial success.

 

Table of Contents

1. Scope of Application


2. General behavior requirements
2.1 Responsibility for the image of the European Aerosols Group
2.2 Compliance with laws and guidelines while considering cultural values
2.3 Responsibility for social basic rights and principles
2.4 Equality of opportunities and mutual respect
2.5 Leadership and collaboration


3. Avoidance of conflict of interests
3.1 Conflicts of interests/protection of interests
3.2 Equity stake and secondary employment


4. Contact with business partners and third parties
4.1 Corruption
4.2 Fair competition
4.3 Donations and sponsoring


5. Dealing with information
5.1 Data protection, data security and protection of intellectual property
5.2 Reporting


6. Environment, energy efficiency, labor and health protection
6.1 Environment protection
6.2 Labor and health protection


7. Use and protection of company property
7.1 Dealing with company property


8. Dealing with the Code of Conduct
8.1 Responsibility for compliance
8.2 Consequences with non-compliance
8.3 Availability

1. Scope of application

The Code of Conduct applies to the complete European Aerosols Group and determines basic principles.

2. General Behavior Requirements

2.1 Responsibility for the image of the European Aerosols Group

The image of the European Aerosols Group is essentially shaped by the conduct, demeanor and actions of every single employee. Each employee takes care not to harm the image of the group when fulfilling their assignments in public – in the home country and abroad. Unacceptable behavior of one single employee can severely harm European Aerosols.


2.2 Compliance with laws and guidelines while considering cultural values

We commit ourselves to observing and complying with effective laws and regulations. As a matter of course this commitment also applies to effective regulations and guidelines as well as acknowledged measures of value of cultural groups and countries where the European Aerosols Group is active. Contraventions are to be avoided by all means. In the case of contravention, each employee must expect disciplinary consequences due to their obligations stipulated in their work contract.


2.3 Responsibility for social basic rights and principles

We respect human rights and advocate their compliance. We honor the basic right of all employees to form unions and workers’ representation. We refuse any knowing use of forced labor and compulsory labor. Child labor is not permissible. The minimum age for admission to employment is observed according to state laws.

Remuneration for performance corresponds to at least the relevant national legal minimum norms.


2.4 Equality of opportunities and mutual respect

The European Aerosols Group as a European-wide enterprise represents diversity, tolerance and equal opportunities. This diversity is very valuable to us as the diverse background of our staff promotes our creativity and allows us to understand our clients better.
We do not tolerate any discrimination and guarantee non-discriminatory treatment regardless of ethnic origin, color of skin, sex, disability, Weltanschauung (view of life), religion, sexual orientation, citizenship, political attitude or social origin.
These principles apply both to internal collaboration and to the conduct of external partners.


2.5 Leadership and collaboration

A trusting and good collaboration is reflected in mutually shared and open information and support. Exchange of information between superiors and staff is a prerequisite for qualified decision making. Staff and particularly superiors ensure a quick and smooth exchange of information.

Every executive manager is responsible for the staff entrusted to them. The relationship with each other must be characterized by mutual respect. Superiors act as role models and align their conduct in particular with the Code of Conduct.

By means of regular information flow and training regarding the applicable duties and power which again relate to the legal requirements or rules and guidelines, the superiors encourage their staff’s compliant conduct.
The executive manager trusts in their staff and entrusts them with as much personal responsibility and freedom of action as necessary to be able to reach the clearly defined, ambitious and realistic objectives.

Within the scope of their management function superiors prevent inacceptable conduct. They are responsible for preventing any breach of rules within their area which might be prevented by appropriate supervision and/or instruction.

3. Avoidance of conflict of interests

3.1 Conflict of interests / protection of interests

We are aware that decisions made in connection with a job for the European Aerosols Group must not be motivated by private interests or personal relationships. Situations, which may lead to a conflict of interests are therefore to be avoided.

We respect the principles of freedom of expression, the independence of the media, the right to information and the protection of personal rights. Each of our employees bears in mind that their conduct as well as their expression of opinion in public does not harm the European Aerosols Group.
Each of our employees respects the accomplishments of their interlocutor and respects their professional and personal reputation. When communicating and realizing interests, the employee only uses legal means.


3.2 Equity stake and secondary employment

Secondary employment is only permissible with prior permission from the company. Furthermore, participation in or a secondary employment with a competitor of European Aerosols is only permissible with prior written permission. This also applies to participation or secondary employment with suppliers or customers. Permission, which has already been granted, can be revoked should justified reasons be on hand.

4. Contact with business partners and third parties

4.1 Corruption

The MOTIP DULI Group does not tolerate any corruption regardless of its nature. This ban applies regardless of who grants privileges for whatever reason and regardless of the country. Laws to fight corruption can be found worldwide and corruption may be considered a serious crime in case of infringement and thus cause substantial damage to the individual but also to the company.
None of our employees may exploit the business contact of the company to their own advantage or that of a third party, or to the disadvantage of the European Aerosols Group. This means in particular that none of our employees grants or accepts illegal private advantages (e.g. material assets, money, services, etc.) in order to influence decisions which should be made based on facts.

We must not be influenced in our business decisions by allowing our suppliers and customers to offer or promise us illegal benefits or by accepting such benefits. If a situation as described above should occur, you should immediately contact your boss. If we are uncertain whether to, e.g. accept a gift, an invitation to a business dinner or an invitation to an event by a supplier or customer, the direct superior is to be contacted immediately. If the examples described above amount to a value of up to € 50.00, it can be assumed that it is no case of acceptance of benefits.

Should reasonable suspicion or legal doubts arise that there is a case of corruption or business crime, each employee is obliged to seek advice and help from those in charge within the company.


4.2 Fair competition

The European Aerosols Group adheres to the rules of fair competition to the advantage of all competitors on the market and advocates ensuring and maintaining free and unadulterated competition while complying with competition regulations and anti-trust laws.
Each employee is obliged to comply with the competition regulations as well as the anti-trust laws.
This means, for example, that no employee communicates with competitors with regard to agreeing on prices, capacities, conditions, profit margins or any other factors. Agreements with business partners and third parties about non-competition, about submitting sham offers in case of calls for bids or about the distribution of customers, areas, markets, or the production plans are also not permissible.

Employees must also not acquire information which is relevant to competition by means of theft, industrial espionage, bribery, wiretap operations or the like.


4.3 Donations and sponsoring

The European Aerosols Group makes donations, that means grants on a voluntary basis.
The sponsorship money is only issued in accordance with the valid laws within the corresponding legal system.
We make monetary and in-kind grants for cultural purposes, education, sports and humanitarian social projects.
Donations are made in a transparent manner and are comprehensively traceable at any time.
No donations are made to political institutions or parties.

Sponsorship contracts, payment of contributions to inter-trade organizations and membership fees which service business interests do not count as donations.

5. Dealing with information

5.1 Data protection, data security and protection of intellectual property

Each of our employees is obliged to comply with data protection legal regulations as well as legal and corporate regulations with regard to information security. Confidential data is to be kept secret and to be protected from improper use. Protection of privacy when using personal data (such as staff, competitors, customers) as well as the security of all business data is to be guaranteed considering effective legal requirements with all business processes.

We are aware that intellectual property is a valuable asset and the basis of our company’s success. Therefore it is necessary to protect this information particularly well. Inventions, recipes, product concepts, details about customers and suppliers as well as other business secrets count as intellectual property.


5.2 Reporting

All of our reports, documentation, messages and announcements are accurate, comprehensible, timely, comprehensive and true. We comply with the rules of the national and European rules and regulations. Our financial documents are the basis for the management of the group and show the course of business and the relevant facts to the stakeholders.

6. Energy efficiency, environment, labor and health protection

6.1 Protection of the environment

We develop and produce paints, technical sprays and putties and fill them in respective containers. We are aware of the responsibility for the environmental soundness of our products and strive, also with regard to energy efficiency to improve it continuously. Minimizing the use of natural resources while considering economic aspects is one basic principle of our corporate philosophy and is rooted in our corporate policy.

Each employee of the European Aerosols Group has to use natural resources economically and purposefully while making sure that the activities are engery efficiency and have as little impact on the environment as possible.


6.2 Labor and health protection

The European Aerosols Group is obliged to provide its staff with safe and healthy work conditions, to monitor these and furthermore to optimize them. Regular training and site inspections support this continuous process.

7. Use and protection of company property

7.1 Dealing with/handling of company property

Company resources, which are provided by the European Aerosols Group, are to be handled appropriately and carefully and to be protected from loss. Only the efficient use of all resources on all levels can secure the long term corporate success. Wastefulness and abuse are not to be tolerated; they harm the operative and financial performance potential and therefore affect each and everyone. Each and every employee can contribute a great deal.

8. Dealing with the Code of Conduct

8.1 Responsibility for compliance

All employees align their actions with the company values and the Code of Conduct and comply with the internal rules and regulations and the valid laws and regulations within their work environment.

Their respective superior is the first person to contact in case of questions or uncertainties regarding the Code of Conduct.


8.2 Consequences with non-compliance

The Code of Conduct of European Aerosols Group combines valid legal and corporate rules and regulations. The obligation to comply with listed conduct regulations of the Code of Conduct directly results either from the laws, corporate rules and regulations, the company’s mission statement or corporate policy or from the work contract. Willful violation of these guidelines leads to consequences within the valid regulations which may result in the termination of the employment contract and in indemnity claims.


8.3 Availability

The Code of Conduct is distributed to all employees. If necessary, the Code of Conduct can be modified considering country specific features.

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