Ethics guideline

Mission

Maintaining a uniform corporate culture is fundamental for a continuously growing medium-sized family company. The owning family and the employees of the Wiebe Group are therefore to develop a powerful, stable and socially responsible company.

All employees are therefore committed to open, honest, fair and trustworthy dealings with clients, business partners, subcontractors and colleagues. This effectively takes into account the values of our society, the principles of correct business dealings and technical progress and technical progress for the well-being of everyone. This culture of responsible, corporate and social dealings is specified by the ethics guideline and the procedure during implementation.

Ethics guideline

As an orientation framework, the ethics guideline aims to ensure sustainable integral business behaviour and contains clear codes of conduct along which we base our actions and decisions. With respect the corporate and company-specific behaviour, the ethics guideline looks at five areas:

  • Working with one another
  • Working with clients
  • Working with subcontractors/suppliers and business partners
  • Working with supervisory authorities
  • Societal and environmental behaviour

The formulated rules aim to act as a constant appeal and incentive for value-oriented conduct. The ethics guideline also includes information about the implementation which contains understandable and clear limits for certain areas and lays out binding compliance.

Working with one another

Our working relationships are characterised by a respectful and trusting based and the acceptance of other opinions. Our communication is always open and honest. We ensure a working environment free of discrimination or harassment. Business information and company secrets are always treated confidentially and with care.

 

Working with clients

In competitive environments we stand out thanks to our professional approach and high-quality work results. We never offer the clients the prospect of personal benefits or gifts. All documents and papers are drafted in line with regulations and are never changed, destroyed or otherwise manipulated for improper reasons.

 

Working with subcontractors/suppliers and business partners

Realistic, unambiguous and mutually agreed contracts are concluded. All dealings are conducted fairly, on an equal partnership-like basis. All employees will refuse to accept money, valuable gifts or any other payment if this could give the impression that it will influence our decisions and/or the scope exceeds normal level and the number of normal business relations.
Actions and decisions are free of any irrelevant arguments or personal interests. Private and personal issues are always set aside.

Any conflicts of interests (for example relatives) that could blur our objectivity are avoided if possible, or otherwise disclosed.

Working with supervisory authorities

When working with public authorities, we always observe valid laws and regulations and work actively with their representatives.

Societal and environmental behaviour

All employees respect human rights, national laws, regulations and religions. Unethical or illegal business practices are rejected.

Guaranteeing safe, environmentally-friendly and healthy work conditions is an on-going task and duty.

Application and scope

The ethics guideline applies to all employees of the Group and their affiliated companies. Subcontractors and suppliers are also included by means of explicit instructions or contract formulations. The guideline becomes valid for all employees on the day it is published.

Final provisions

Breaches of the laws, regulations, values and standards in this guideline may have consequences for the employees under labour laws that can lead to termination without notice. Also, breaches can lead to criminal charges and claims for damages. Business partners run the risk of immediate termination of business relations in the event of breaches.

Implementation and explanations

The ethics guideline should be observed and repeatedly discussed. Its implementation is supported by the following three measures, although these aids and rules cannot over all possible situations that can occur on a day to day basis. Our personal behaviour and loyalty plays a positive role on its implementation.

(A) Self-check by answering the following questions

The decentralised nature of the ‘construction sites’ means that they have a high level of independency and self-responsibility. Addressing the following questions specifically helps in case of any difficult questions, doubt or uncertainty with respect to one’s own voluntary commitment to this guideline:

  • Have I informed colleagues, line managers and discussed with them or asked for advice?
  • Is the action/decision compatible with standards and laws?
  • Am I jeopardising the integrity/reputation of the company, the client or myself?
  • Was the decision reviewed neutrally, was it agreed upon objectively?
  • Does this action damage my company?

(B) Contact and communication help

In the case of any issues referring to ethics management and compliance with the guideline, each employee should initially seek to clarify the situation within his/her own organisation within the Group. If this is not possible or appropriate, a special mailbox has been set up to help communication that does not go through normal channels. This mailbox has been specifically installed for wishes, information, ideas, criticism, complaints etc. and guarantees all persons or company neutrality.

The information received here will only be registered by the internal revision team. It will be treated confidentiality and, depending on the content, will be forwarded anonymously to the affected divisions for review. If this information provides sufficient evidence of actions that could be harmful for business, the IR team immediately investigates the information with due care.

The reviews have the following goal: Objective clarification and assessment of the issue with the following consequences:

  • to refute or offer protection against incorrect allegations or
  • consistent collection of evidence of actions that could be harmful for business.

Partners and managing directors of the holding are informed about the number of received reports and the information they contain at least once a year. Regardless of this, it ensures correct and punctual inclusion of the organisation of the affected companies, if personnel decisions or action needs to be taken.

 

The internal mailbox has the post-box address 33 01 52 in 28331 Bremen.

(C) Codes of conduct, regulations and value limits

Gifts

  • It is prohibited to accept any kinds of gifts from business partners, both against payment or for free. Exceptions are normal business advertising gifts on an irregular basis (e.g. calendars) the value of which does not exceed 30 €.
  • Invitations to dinner are allowed within the normal scope of business relations if the invitation is voluntary.
  • Any participation in planned customer events must be reported to the line manager.
  • Sponsoring of events by companies of the Wiebe Group or parts of the group must be approved. Voluntary donations are allowed with no expectation of any reciprocal consideration.
  • All gifts to business partners are prohibited, if this could influence their business dealings.

Company assets

  • All employees have a duty to protect company assets at work and to handle them in an honest, responsible and integral manner.
  • Property belonging to the Wiebe Group may only be used for company purposes or approved purposes and must be handled carefully. All employees have a duty to protect property against loss, theft, damage or misuse.
  • All business documents, work materials and any other paperwork or copies and electronically saved data must be stored carefully and returned voluntarily when the working relationship ends.
  • Travel expenses and construction site petty cash accounts must be listed and billed according to the costs with receipts.

Price fixing

Illegal price fixing or other illegal activities that could impact prices or other conditions or hinder or impeded a free and fair competition are prohibited.

Conflicts of interest

Possible conflicts of interest must be avoided. If there are any circumstances that cannot be avoided, these must be disclosed to the line manager immediately after becoming aware of the potential conflict of interest. The line manager decides about appropriate action to avoid ties and overlaps. In particular conflicts of interests may be:

  • Interests in subcontractors, suppliers, customers or other companies with which the Wiebe Group has or intends to have business dealings.
  • Own construction activities (e.g. building construction) by employees, if the order value exceeds a sum of 10,000 €.
  • Intended, private commissions7employment of a company or personnel of the Wiebe Group in their own name and own account.

Confidentiality

  • Confidential business information, business and operating secrets may not be disclosed to or forwarded to third parties.
  • It is prohibited to use this confidential information to the detriment of the Wiebe Group, to one’s own benefit or the benefit of a third party.

July 2014, signed The general management

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