Our code of conduct2019-11-29T13:33:25+01:00

Code of Conduct of Creditreform AG

As subsidiary company of the Creditreform AG, Boniversum has to comply with the Code of Conduct of the AG. All members of staff are committed to the appointed standards, mentioned in the Code of Conduct, and have to consider and implement the appointed standards of the daily working process.

1. Foreword

Complying with prevailing law, acting responsibly towards our environment, and behaving ethically towards society, Creditreform AG companies and their staff and business partners are fixed elements of our system of values and our actions.

Creditreform AG companies are active in diverse business fields ranging from marketing services and personal-information services through to compliance services, rating services and credit services for third parties in Germany – also partially abroad. The minimum standards set out in this Code of Conduct form the basis of our common, ethical, social and environmental responsibility, irrespective of the country or cultural circles in which we work.

Our Code of Conduct is binding for all staff of Creditreform AG and the companies in which Creditreform AG has a majority holding; it provides you, as a staff member or manager, a common guideline and orientation framework for acting in compliance with the law, and behaving responsibly towards the environment, our business partners and the public. All of us must observe and implement these standards in our daily work processes. Should individual companies have implemented their own Codes of Conduct, then those shall apply accordingly.

The Creditreform AG Management Board

2. Observance of statutory principles

The observance of prevailing national and sector-specific regulatory standards and laws is a matter of course. This includes observing all the laws and regulations connected with our business areas. If regulations in specific countries or for specific product areas are stricter than the generally-valid regulations, then the stricter regulations must be observed. Generally-binding standards of occupational and interest groups to which our organisation belongs should be regarded as equivalent to statutory regulations.

All managers are responsible for knowing the valid laws and regulations applicable to their duties and spheres of responsibility, and for communicating these to their staff and ensuring that they are observed.

3. Respect for staff

Discrimination because of Religion, family status, gender, physical or mental disability, sexual orientation, membership of an union or political party etc. is not tolerated.

Each individual has the fundamental right to his or her own opinion and to be treated respectfully. At all levels, we foster a spirit of open dialogue characterised by tolerance and respect; this applies not only for managers vis-à-vis their staff, but also among the staff members and managers, themselves. Discriminatory behaviour is not tolerated under any circumstances, regardless of the grounds.

All supervisors, but also staff members among themselves, are responsible for ensuring that misgivings, critical aspects and misconduct can be openly addressed and articulated. Managers should foster an atmosphere of open and anxiety-free dialogue without reprisals, and encourage their staff to speak openly.

In our corporation, we foster an atmosphere of mutual esteem by respecting others’ individuality, and do not tolerate any form of discrimination or harassment due to age, gender, religion, abilities, sexual orientation or origin.

If anyone draws attention to critical behaviour or misconduct, intimidation attempts and reprisals from either side are not to be tolerated.

Criticism should be voiced objectively and matter-of-factly. It serves to address misconduct openly without harming the criticised person’s dignity. The criticised person must address the criticism and reflect upon his or her conduct and actions.

Managerial staff have a duty to care for their employees – be that with respect to limiting their workloads and working hours to levels which do not pose a health risk, or serving as contacts for personal concerns and emergencies which could endanger their employees’ physical or mental health.

4. Respect for property

The respectful handling of property is one of our principles. We respect and protect the property of others, regardless of whether it belongs to colleagues, our employer, customers or suppliers. Company property is used exclusively for the business purposes for which it is intended.

Property is to be handled with care and protected against damage. Should property be dam-aged, its owners must be informed and damagemitigation measures initiated. For property which is harmful to third parties, employees and supervisors are equally obliged to stem the source of the harm and inform the owner.

Any form of theft or improper use of others’ property for third parties or for oneself is prohibited. The term “property” is used to mean both material as well as immaterial assets.

Against the background of our business activities, protecting our business partners’ data and information, as well as their intellectual property (i.e. the observance of copyright law), is of prime importance. Appropriate company- and IT-specific monitoring measures and policies have been implemented to prevent all forms of non-compliant usage.

Business data and information may only be saved and processed in the intended IT systems and only for the agreed business purpose.

The same applies to compliance with the effective data protection laws on collecting, saving and processing any kind of personal data.

5. Confidentiality of information / publicity

Company intern information as personal data, product samples, patents or plans are subjected to strict confidentiatility. Also data third parties as information of family, friends, neighbourhood, sports club or similar.

Information which becomes known to us in the course of our business, and which is not public, is subject to strict confidentiality; it is immaterial as to whether the information concerned is company-internal or belongs to our business partners. Such information may neither be communicated company-internally, nor to outsiders or third parties.

Media inquiries about our business partners or company should be forwarded to our supervisors.

6. Relations with business partners

Business partners are not limited to just our customers, but also include suppliers, consultants and representatives of institutions and the public sector.

Dealings with our business partners must be fair, transparent and free of incorrect / misleading information. This not only applies to personal conversations and bids, but also to the way we present ourselves in the media, Internet and sales documents.

Competitive pricing agreements and unethical competitive practices which prejudice fair competition are prohibited.

At the same time, we also expect our business partners to observe the prevailing laws and regulations, as well as this Code of Conduct, and screen e.g. our suppliers for this to a reasonable extent.

Bribery and corruption in any form are forbidden. Business gifts – e.g. in the form of invitations or promotional events – are permitted if they are proportionate and do not influence the decision maker’s actions. Such gifts may not be of a high value or serve as inducements. These rules apply both to givers and recipients alike. For further details, please refer to our Anti-Corruption Policy.

Gifts to officeholders and dignitaries, and representatives of state or municipal bodies and public-sector employees are subject to very strict conditions. Often, such persons are prohib-ited from accepting any form of gifts, regardless of their value. If gifts are unavoidable – e.g. in the framework of a business meal – appropriate handling of the situation should be dis-cussed with the business partner or the giver’s own supervisor beforehand.

7. Humans and the environment

Observance of human rights, protection of physical and mental health and of the environment are a part of our self-perception and voluntary corporate commitment.

We provide for fair working conditions and reject child labour, and discrimination and exploitation in any shape or form.

8. Avoiding conflicts of interests

Basically conflicts of interest can arise in connection with any businesses for Creditreform AG and its companies. In accordance with this Code of Conduct and the relevant regulations, it is necessary that both actual and potential conflicts of interest have to be identified and adequately regulated.

In particular it should also be avoided that a conflict of interest damages the customer´s or supplier´s interests. Conflicts of interest can arise between many different groups of people. Next to conflicts of interest that may arise between Creditreform AG or one of its companies and a customer or supplier, potential conflicts of interest may occur between a customer and another customer, an employee and a customer or a supplier or between two different Creditreform AG companies.

But what exactly are conflicts of interest and how do they arise?

The term of conflicts of interest includes a variety of behaviors. Basically a conflict of interest arises when two or more persons have different, conflicting interests and there is a duty of due diligence and loyalty between them. An employee may be involved in a conflict of interest in the course of daily work that may affect the professional judgment or objectivity or otherwise influence the proper performance of the employee’s duties and responsibilities.

Failure to identify and adequately regulate conflicts of interest may result in adverse consequences for customers or suppliers, Creditreform AG or one of its companies or employees. All managers are responsible for implementing controls and procedures to detect, escalate and regulate conflicts of interest. However, each employee is responsible for identifying and escalating potential conflicts of interest so that they can be reasonably regulated.

If actual or potential conflicts of interest are not identified, escalated and regulated, severe fines and other sanctions for Creditreform AG, one of its companies or employees could be the result. Such sanctions could have negative effects on the reputation of Creditreform AG or one of its companies and could lead to a loss of confidence.

8.1 Basic approach

We principally expect our employees and supervisors to be familiar with the laws and regulations applicable to their fields of work. Moreover, nothing can substitute personal integrity, sensitivity and common sense. These must be applied by all staff members in their day-to-day work.

We expect situations to be avoided in which employee’s (in the broadest sense, also their relatives’) business and private interests coincide and result in a conflict. All staff are therefore required to fundamentally segregate their private interests from those of the company.

If you are faced with a difficult situation and are uncertain of how to proceed, you should ask yourself the following questions:

1. Are my actions legal and in compliance with the prevailing laws and company policies?
2. Is my decision uninfluenced by personal interests, and can I reconcile it with my personal conscience?
3. Is it consistent with this Code of Conduct and the supplementary regulations of my company?
4. Would my actions stand up under public scrutiny? How would my actions be looked upon, were they to become public?
5. Do my actions safeguard the Creditreform group’s good reputation?

If you can answer all these questions with “yes”, then your actions or decisions are probably correct and defensible. If you are uncertain, you should seek qualified advice from one of your competent supervisors or one of the contacts listed below until you are absolutely certain your decision is the right one.

We foster an atmosphere of anxiety-free dialogue. If anyone draws attention to critical behaviour or misconduct, intimidation attempts and reprisals from either side are not to be tolerated.

8.2 Investigation of a reported issue

As soon as an issue is reported, the situation is first assessed to determine the scope of the investigation. The person concerned will be informed of the assessment results, and may possibly be invited to participate in further discussions to provide additional information.

The person being investigated will be updated on the status of the investigation and its prospective timeframe. Certain information regarding the investigation and potentially ensuing disciplinary measures may, however, have to be withheld from the employee for confidentiality reasons. All information connected with the investigation must be handled confidentially.

The goal of this Code of Conduct is to foster an open corporate culture in which honesty, integrity and fairness can flourish and where everyone’s personal views and opinions are respected by all. It also aims to encourage staff to report any serious concerns.

While the desired results cannot always be guaranteed, each notification of a potential compliance breach will be treated fairly and appropriately. If everyone observes this Code of Conduct, it will help to achieve these goals.

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