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.