Code Of Conduct
atene KOM GmbH’s principles
The company’s personal responsibility
atene KOM GmbH undertakes to comply with and implement all laws and regulations applicable in Germany, regardless of any economic disadvantages resulting from such compliance. It expects the same from its business partners. All executives are instructed to familiarise themselves with the basic rules and regulations in their division, so that they in turn can pass on their knowledge to atene KOM GmbH’s employees.
Compliance with the globally applicable regulations for the protection of human rights is a matter of course for atene KOM GmbH. It opposes all forms of modern slavery, human trafficking and child labour.
atene KOM GmbH is synonymous with open and honest communication. Employees may also contact their superiors or the management team if they have any critical issues. We believe that a trustful cooperative relationship leads to misconduct being recognised at an early stage, corrected and even avoided in future. Our executives are urged to always encourage employees to engage in open discussion.
atene KOM GmbH attaches a great deal of importance to traceable, established processes. We strive to achieve the greatest possible level of transparency both in our own interests, as well as those of our business partners and customers. To achieve this, it is vital that all processes in all workflows are always documented.
atene KOM GmbH supports a wide range of different projects. These orders are strictly separated from one another. To this end, we work with a role authorisation concept. atene KOM GmbH’s various departments are separated from one another so that the different goals cannot lead to conflicts of interest or information that people are entrusted with being exchanged.
atene KOM GmbH believes strongly in trust and respect. We can only achieve the utmost in productivity, competitiveness, innovative capability, creativity and efficiency if we cooperate with one another respectfully. All employees should treat one another with courtesy and mutual respect. atene KOM GmbH strictly prohibits harassment, any form of unwanted physical contact, bullying and intimidation, and such conduct may result in disciplinary action.
atene KOM GmbH selects its employees based solely on their qualifications and skills. All employees are offered the same opportunities. Discrimination based on gender, age, disability, sexual orientation, pregnancy, parenthood, marital status, religion, ideology, ethical or national affiliation, skin colour, political opinion or social origin is rejected without exception. atene KOM GmbH is synonymous with diversity, promotes tolerance and is committed to inclusion.
atene KOM GmbH’s employees have established a works council. Their aim in doing so is to achieve a fair balance between different parties’ interests. The works council should seek to achieve open, trusting and constructive dialogue.
atene KOM GmbH complies with the legal provisions aimed at ensuring fair working conditions. Particular emphasis is placed on the regulations concerning remuneration, working hours and protecting privacy. atene KOM GmbH also promotes balance between its employees’ work and family lives by offering flexible working hours models.
Occupational safety and health protection
atene KOM GmbH promotes a healthy and risk-free working environment. The laws and regulations concerning health and safety in the workplace are observed. All executives shall ensure that adequate procedures and safeguards are in place to ensure health and safety in the workplace.
Protecting intellectual property
‘Intellectual property’ is defined as a right to an intangible commodity. As it is protected by law and/or as a trade secret, any reproduction requires permission. Every employee is instructed to protect atene KOM GmbH’s intellectual property against attacks by third parties or loss. Other people’s intellectual property must be respected.
Trade and business secrets belonging to atene KOM GmbH or its business partners shall be treated with absolute confidentiality by atene KOM GmbH and its employees, and may not be made accessible to third parties. They may also not be used for employees’ own private purposes.
‘Insider information’ is defined as specific information about circumstances that are not publicly known which, if they were to become known, could have a significant influence on the price of securities or similar financial instruments. Insider trading is a criminal offence in Germany, as it affects the functioning of the capital market. atene KOM GmbH expressly rejects insider trading and explicitly instructs its employees not to use insider knowledge neither for personal gain nor to derive advantages for atene KOM GmbH or third parties.
Accounting and bookkeeping
All business transactions, assets and liabilities are recorded and documented in full. The company’s business transactions and documents must be correct and proper. atene KOM GmbH prohibits any form of balance sheet manipulation.
Preventing money laundering
Money laundering occurs when funds or other assets derived directly or indirectly from criminal activities are introduced into legal economic circulation. All employees are called upon to report unusual financial transactions.
Terrorist financing occurs when funds or other resources are provided for terrorist criminal offences or in support of terrorist groups. All employees are required to report suspicious transactions.
atene KOM GmbH always makes donations in its own name. Compensatory measures are not expected. The recipient, the purpose of the donation and the confirmation of the donation are all documented in full. No direct or indirect donations are made to public bodies, political organisations, parties or individual politicians.
atene KOM GmbH refrains from exerting unfair influence on politics and legislation and complies with the legal regulations on lobbying.
Protecting company assets
atene KOM GmbH uses the company assets for their intended business purpose. Abusive, illegal or unauthorised use, especially for private purposes, is prohibited. atene KOM GmbH strictly prohibits all forms of fraud – whether to the detriment of company assets or to third parties’ assets.
Conflicts of interests
When making decisions on official business, every employee is required to check whether the decision is influenced by private interests. Private and business interests must be separated, so that decisions can be made neutrally and rationally. atene KOM GmbH urges its employees to consult with their superiors if they potentially have conflicts of interest. These arrangements shall be documented.
Responsibility towards business partners and third parties
Relationships with business partners
atene KOM GmbH considers itself to be a reliable and legally compliant business partner. We want to face today’s challenges and always find the best solution for our customers. Executives are urged to familiarise employees with their contractual obligations towards our contractual partners.
Dealing with political institutions and authorities
Special care must be taken when dealing with political institutions and authorities. These business relationships are often subject to more stringent requirements. Honesty, transparency and compliance with applicable law should be a matter of course in everything we do.
atene KOM GmbH is synonymous with fair and undistorted competition in the interest of all market participants. This is an essential prerequisite for a social market economy. To protect this competition, atene KOM GmbH naturally complies with the relevant legal requirements.
atene KOM GmbH sees itself as its customers’ service provider. It attaches a great deal of importance to establishing trusting, successful and long-term customer relationships. We want to offer our customers the highest level of quality with our products and services.
Information about products and services
atene KOM GmbH always provides truthful information with regard to its products and services. We believe that false statements can put existing business relationships at risk, so they must be avoided to protect atene KOM GmbH’s good reputation.
atene KOM GmbH respects confidentiality when collecting, storing, processing or transmitting personal data belonging to employees, customers or other third parties. We act in line with the principle of data minimisation and encrypt or delete data whenever possible. All employees receive training on data protection. Those employees who handle personal data also receive advice and support from the relevant department.
Use and security of IT systems
atene KOM GmbH takes appropriate security precautions when handling sensitive data and to protect intellectual property by using IT systems. All employees receive regular training on information security. The IT resources available in the workplace belong to atene KOM GmbH and are company property. They may not be used for private purposes. atene KOM GmbH’s employees are required to protect IT systems’ security from internal and external misuse.
Our employees’ responsibility
atene KOM GmbH respects the right to freedom of expression. atene KOM GmbH’s employees act as representatives of the company in public. Executives are role models for all employees. All employees are aware that they must refrain from any conduct that could damage the company’s reputation. atene KOM GmbH’s good reputation is decisive for its economic success.
Violations of law or of the code of conduct must be reported. Superiors should pave the way for this and be approachable. Irrespective of this, the statutory reporting obligations – especially when observing criminal offences – must be complied with.
Internal early warning system / communicating risk
atene KOM GmbH will set up an internal reporting system through which whistleblowers can report in writing and in complete confidentiality any violations of national and EU law. If the report is made in the belief that it is true, the whistleblower will not be facing reprisals. atene KOM GmbH will do everything in its power to remedy the situation. Throughout the entire clarification process, executives in particular shall ensure that data protection regulations and the provisions on keeping business secrets are complied with.
Prohibition of corruption
atene KOM GmbH vehemently rejects any form of corruption. Our employees receive training on corruption prevention on a yearly basis. All employees are aware that gifts or other advantages are only permitted if they are customary in the business, are of low value and ethically unobjectionable, and are not related to any compensatory measures. No employees may demand gifts or other advantages from business partners.
Professional activities must not be used to obtain private advantages. All employees are prohibited from accepting gifts. This does not apply to low-value gifts that it would be socially inappropriate to refuse due to local customs. Operational decisions must not be influenced by this. Under no circumstances are cash, vouchers or similar tokens to be accepted. If employees are invited to meals, the limits of customary business hospitality must be examined. If the invitation serves the purpose of exerting undue influence on professional decisions, it must be rejected.
Offering gifts to third parties
atene KOM GmbH instructs its employees to generally not distribute gifts and invitations to third parties. Customary occasional and promotional gifts, as well as invitations that are customary and polite in a country, are excluded from this rule. Employees can contact their superiors if in doubt.
Responsibility towards nature
atene KOM GmbH is committed to sustainable environmental and climate protection. When developing new products and services that we provide, we ensure that the impact on the environment and climate is kept as low as possible. A climate protection officer has been appointed to assist us in improving our environmental balance. Every employee is required to act in an environmentally conscious manner.