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Personal and Professional Integrity

Compliance at BARTEC

Responsible, ethically correct, and lawful conduct is just as essential for the BARTEC’s success of BARTEC as our innovative strength, technical performance, quality, and customer orientation.

Compliance is an essential component to ensure the sustainable success of the company, to protect our employees, managers, and the organization behind them from unnecessary risks, and pointssteering everyone in the right direction in cases of doubt.

BARTEC's compliance organization acts on three levels: prevention, identification, and response. It is responsible for all compliance activities, coordinates training and seminars, supervises compliance with internal and external regulations, and is responsible for the development and implementation of globally binding internal governance and compliance standards.

In order to anchor compliance at the higher managerial level, BARTEC has created an overarching corporate function in the form of the Compliance Office.

As trusted advisors, compliance ambassadors provide support Trusted Compliance Ambassadors throughout the world provide support in maintaining and continuously improving our Compliance Management System.

Identifying compliance risks at an early stage

In order to identify compliance risks at an early stage, BARTEC offers its employees and business partners the opportunity to report compliance violations in confidence at compliance(at)bartec.com . All information provided is treated confidentially. Incoming reports are not traced, and submitter information is not recorded.

Email
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Code of Conduct

Acting responsibly, in an ethically correct and lawful manner is just as important to the success of BARTEC as our innovative force, technical performance, quality standards, and customer orientation. The reputation which we have established with a great deal of dedication in relation to our customers, shareholders, business partners, and in public can easily be damaged by individual legal violations.

Our common objective is to further strengthen BARTEC’s position as number 1the leader in the field of industrial safety technology. For that reason all of us are required to behave in a responsible manner and to act in accordance with the law. This Code of Conduct defines the ethical and legal framework within which we act. It sets out the fundamental principles of our conduct within the BARTEC Group and in our relations with business partners and the public. It presents the principles of our corporate actions and is an expression of our corporate values. Acting responsibly means acting lawfully just as much as it means acting ethically.

These principles of conduct constitute the binding benchmarkfor the actions of all staff. Our principles of conduct do not relieve anyone from their personal responsibility. However, we ask all employees to request advice and help when faced with decisions on ethical or legal issues or if they become aware of forms of conduct in their work environment they consider difficult or concerning. Only transactions that meet this standardadhere to these principles are BARTEC business transactions. The Compliance Office acts as the bridge between law, conscience and culture.

Our Code of Conduct serves as guideline for conduct that complies with and exemplifies the corporate culture of the BARTEC Group. It is based on safety, integrity, and sustainability. Above all, the binding principle of conduct serve to protect our employees, managers, and the organizations behind them. In everyday business the The Code of Conduct is designed to help find the correct and appropriate answers to the ethical and legal questions that arise in everyday business, during strategic considerations and in decision-making processes. All members of staff are called upon to apply the principles of conduct every day at the BARTEC Group.

Our business relations with customers, suppliers, and business partners are determinedshaped by ethical conduct. We conduct our business in a manner that is open, honest, and ethically responsible. Our action is always characterized by fairness, good faith, and integrity. We say what we mean and do what we say. We expect the same from all our employees and from everyone we do business with.

We maintain no relations with customers, suppliers, or competitors that might influence our decisions on behalf of BARTEC. Actual or potential conflicts of interest must be avoided.
Our employees avoid conflicts between their private interests and those of the company. We do not allow our decisions to be swayed by private interests or personal relationships. Business relationships are based on objective criteria such as price, quality or the existence of fair cooperation arising from past, pre-existing collaboration. Business relations from which purely personal material or other benefits may be derived shall not influence the signing of a contract or the continuation or termination of a business relationship. BARTEC welcomes any voluntary work by its employees as long as it is compatible with their contractual obligations towards BARTEC in accordance with their employment contract.
When expressing a private opinion in public, employees may not create the impression that this represents the position of the Company. If an employee faces an actual or potential conflict of interest, he must promptly notify his line manager and/or the Compliance Office so that the conflict can be jointly resolved.

When expressing a private opinion in public, employees may not give the impression that this represents BARTEC’s position.
If an employee faces an actual or potential conflict of interest, they must promptly notify their supervisor and/or the Compliance Office so that the conflict can be jointly resolved.

We take our decisions freely and independently, without allowing the development of and avoid establishing dependencies or biases. We do not accept no preferential treatment by suppliers, service providers, or customers. Material or moral dependencies must not play any part in our dealings with business partners.
 

We reject any kind of “you scratch my back and I’ll scratch yours” business policy. We only accept invitations from business partners to events or business dinners only when these have a demonstrable business purpose. The invitation must be proportionate to this business partner, and must not go beyond common hospitality.
Gifts from business partners must be within legal limits and be appropriate in terms of type and extent.

Invitations from business partners to events of a predominantly private character are permitted in approved exceptional cases if the principal costs of the event are borne by BARTEC or by the employees themselves.

We are committed to fairness in competition. Only with fair competition as a prerequisite for a free market can develop freely. Every employee of the BARTEC Group is obliged to be aware of and to comply with the rules of fair competition.
Wherever BARTEC operates, the Company adheres to antitrust and trade laws, laws on pricing, competition, and consumer protection. During their business activities with customers, suppliers, and competitors, employees of the BARTEC Group must at all times act within the limits permitted by law. This means that they may neither engage in price fixing, nor come to secret agreements about production, supply, or the sharing of markets. Employees of the BARTEC Group may not participate in unfair trading practices.
We do not tolerate illegal agreements with competitors. Even the appearance of improper agreements with other market participants must be avoided. If in doubt, the Compliance Office must be consulted.

We are committed to integrity in our business and social activities. Decisions about business dealings with our business partners are based exclusively on facts that can be objectively evaluated, such as quality, price, and performance. They will not be promoted by gifts, donations, bribery, or corruption. The principles of honesty and integrity must be complied with in all business and social activities and at all times.
Relationship management is part of business success. It is conducted neither in legal grey areas nor using inadmissible means. Employees of BARTEC do not accept bribery directly or indirectly, nor do they make any such offers themselves. Bribery in business transactions and towards public officials is a criminal offence. When dealing with government offices or authorities, no payments or benefits to be promised or granted in order to influence the decisions made by public servants or other office holders in favor of BARTEC.
We do not make any gifts for the purpose of inappropriately influencing our position in the market. We do not accept any gifts intended to influence the awarding of contracts. Gifts or benefits which may influence business decisions are impermissible and must neither be offered, granted, requested, nor accepted. This also applies if they might merely create the appearance of impropriety, and, in particular, to the initiation of contracts and the conclusion of business deals.
As a responsible member of society, the BARTEC Group makes donations of money and donations in kind for educational, cultural, social, and sports purposes. Donations must always be transparent. The recipient of the donation and the purpose must be known and clear.
Donations to individuals, organizations operating for profit, and organizations pursuing a purpose without tax privileges, as well as donations to private accounts and donations that damage the reputation of the BARTEC Group are prohibited.
Political donations are precluded; this applies equally to individuals, parties or other political organisations.
The BARTEC Group can make contributions in the form of money or in kind to an event organized by a third party. When such contributions are connected to counter-performance in the form of advertising or customer loyalty measures, this is referred to as sponsorship. Sponsorship requires a written agreement, a serious business purpose, an appropriate ratio between benefit and equivalent value, and complete transparency.
The executive management of the BARTEC Group makes all decisions about donations and sponsorships that go beyond local and temporary activities or minor donations.

We respect all national and international customs legislation as well as legislation relating to exports, antiterrorism, and embargoes.
 All employees are obliged to adhere to the limitations of and bans on export and domestic trading within specific goods, services, or technologies. The trade bans and restrictions relating to international embargoes and the international fight against terrorism, which may also affect capital and payment transactions, must be strictly observed. National (German) and European export control provisions determine our actions.
If doubts persist about whether the use or distribution of our products is permissible, a decision must be made by Corporate Compliance & Legal Affairs together with the executive management.

All employees are fundamentally responsible for ensuring that customers have confidence in the safety and quality of our products. The safety of products and/or processes is our number oneutmost priority. We select our suppliers according to the safety of their products and compliance with quality standards.

We have developed professional product safety guidelines and programs that are based on solid scientific principles, practical operating procedures, the latest technologies, employee training, and customer information.

The products we sell not only meet statutory requirements and industrial standards/guidelines, but usually exceed them. Every employee is responsible for product safety. Our aimpriority is to meet the expectations of our customers at all times.

The material and intellectual property of the BARTEC Group must be protected from loss, theft, and misuse. The value of our company is based on the ideas and the inventiveness of the people who actively promote the success of the BARTEC Group and who have done so in the past. Successful knowledge management has continued to pass on this added value from generation to generation. Inventions, patents, names, and other expertise are extremely valuable in this respect, as are our trademarks. We protect these intangible assets, as they are of considerable economic significance to the future of our enterprise.
We undertake to respect the material and intellectual property of third parties and reject illegal ways of acquiring information. Company secrets include all information whichthat is not publicly accessible and which is very important to the BARTEC Group or its competitors, as well as any information which only the company possesses.

We take great care to protect confidential information. Company secrets and knowledge about future developments must not be passed to third parties, let alone be published, without legal safeguards. Confidential information includes documents, facts, data, and knowledge concerning profit figures, new products, ideas for research and development, business or marketing strategies, customer insider information, personnel matters, investments and holdings, manufacturing processes, and internal guidelines and procedures. No employee may misuse the intellectual property of the BARTEC Group for histheir own purposes. All employees are called upon to protect data against unauthorized access by third parties and to avoid opportunities for third parties to access business documents. IT security, data security, and data protection are top priorities for us.

We respect the property and equipment of the Company and treat them with care. The financial assets and funds of the BARTEC Group may not be used for unlawful purposes.
Production areas, laboratories, offices, and workstations must always be kept clean and tidy. We use the equipment made available to us by the Company, e.g. telephones, company cars, and computers, in accordance with the local guidelines of the BARTEC Group.
The inappropriate use of computers is not permitted. Personal use should be proportionate and kept to a minimum.

Transparent, prompt, and reliable internal and external communication is an important part of our corporate culture. The misinformation of employees and colleagues, the public, the market and our customers is not acceptable to us.
Customers should receive access to the information needed to make a sensible business decision in a suitable manner. This may be by means of general written product information or through sales representatives, for example. BARTEC takes customer complaints very seriously and processes them promptly and fairly.
All information that is provided to the public is truthful. We aspire to faultless quality. Improper, ambiguous, incomplete, or ill-considered statements may be misinterpreted, misused, or taken out of context, thereby causing us considerable damage. For this reason, communication via email and new media must also be conducted correctly.
As a matter of principle, information may only be provided to the public by authorised members of staff.  Anybody who appears in public as a representative of BARTEC without authorisation acts as a private individual.
Corporate Compliance & Legal Affairs must be consulted immediately in the case of enquiries by investigating authorities. 

Important business processes are appropriately documented in the accounts. The systems deployed ensure that accounting information concerning business transactions is completely and correctly recorded. Keeping records and files that are complete, clear, and understandable is therefore a matter of course for us. Records and files must be kept in such a way that auditors and financial authorities are able to follow the system used and the contents at any time. Our processes are transparent and structured such that they can always be continued by other employees. Legal or internal obligations to retain records must be met. Documents which relate to procedures of authorities or courts of law may not be destroyed. Any documentation must be formally correct and be consistent in terms of content so that it may also be shown to third parties when required.

The conduct of each employee defines the public perception of BARTEC. For this reason, we demand appropriate and courteous behavior toward colleagues, employees of suppliers and customers, and towards other business partners. 

We undertake to treat one another with respect. Our employees are the foundation of BARTEC's success. To ensure that their strengths can fully develop, we create a work environment which encourages appreciation and promotes integrity.
We tolerate neither discrimination nor harassment. Performance and conduct in the spirit of teamwork are important to us, irrespective of age, origin, gender, or ethnic group. We judge the result of an individual’s work objectively, regardless of political commitment, religion, physical constitution, or sexual identity. For this reason we do not tolerate defamation, intimidation, threats, or assigning blame to others. Fairness, respect, team spirit, and forthrightness define our cooperation with line managers, colleagues, and other employees. These principles also apply to our conduct towards external partners. We respect and promote employee rights and pursue a relationship with employees in a spirit of partnership aimed at finding solutions.

We specifically promote cooperation between different divisions and countries. The decisive criteria for selecting and promoting our employees are performance, the ability to develop, and the personal qualifications of each individual. We are committed to a culture of learning where objective feedback is desired and appreciated by all involved but where personal attacks are rejected.

We behave professionally and appropriately at all times. Our work requires clear thinking and often the ability to react quickly; the safety of fellow employees and consumers depends on this. Alcohol, drugs, and taking excessive amounts of medication limit the performance of an employee. We follow strict workplace guidelines for smokers and for alcohol and drugs use.

The BARTEC Group encourages safety, health-conscious conduct to protect the lives and health of its employees, to safeguard its assets, to guarantee business continuity, and to build public trust. All companies in the BARTEC Group undertake actions to provide a safe and productive work environment for their staff. Safety is particularly important in production areas, which therefore have their own safety regulations. Safety rules have been conceived for each workplace, and these must be followed. The companies in the BARTEC Group comply with all valid laws concerning health and safety; frequently they satisfy even more stringent criteria than those prescribed by law.

We respect the principles of the Universal Declaration of Human Rights. We strongly condemn forced labor, child labor, and all practices in which people are exploited or exposed to dangerous conditions.
We comply strictly with laws regulating the minimum age for employment and other employment conditions. The minimum age for employment at the BARTEC Group corresponds to the Convention of the International Labour Organisation and/or the age prescribed under local law if this is greater.

We are committed to sustainable entrepreneurship. We comply with laws and regulations governing environmental protection. We are committed to improving our environmental performance by supporting the transfer of expertise, best practice and technology. We go to great lengths to minimise the impact of our business activities on the environment. We achieve this objective through the economical use of energy and water resources, careful use of consumables in everyday working life, the monitoring of air pollution, limiting the use of packaging and by generating the minimum amount of waste.

In addition to the parties in our supply chain, the focus of our social responsibilities is on  all aspects of society affected by our business activities. Through interaction with the various parties (suppliers, customers, consumers, employees, and the community) we ensure that the social activities of the BARTEC Group effectively support improvements (under consideration of local conditions) and are beneficial to both the enterprise and to the community. We compile data on environmental impact and performance, determine monitoring principles and regularly check the progress made. We expect our suppliers to systematically improve the social, environmental, and ethical quality of their products and production, and support them in these endeavors.

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Whistleblowing

Channels for reporting misconduct

The good reputation we have earned among our customers, shareholders, and business partners, as well as among our employees and the public, can be seriously damaged by even the smallest infringement. It is, therefore, essential that reliable reporting channels are available. These help ensure effective compliance by facilitating the reporting of potential misconduct and enabling possible violations to be thoroughly investigated and clarified.

We provide various reporting channels through which both employees and external stakeholders can report potential violations. BARTEC employees can make confidential reports directly to their supervisors or to senior management, as well as to the the reporting office representatives of the respective locations or BARTEC Compliance Office. They can also contact Safecall if they wish to remain anonymous.

Senior Management

Potential violations can be reported directly to supervisors or to senior management.

Compliance Office

The BARTEC Compliance Office is happy to assist employees reporting potential compliance violations, whether in person, by phone (+49 1636 597 316), or via email at compliance(at)bartec.com.

Whistleblowing Service

Acting responsibly means acting in a lawful and ethically correct manner. The BARTEC Group constantly strives to justify the confidence customers, business partners, shareholders, and employees, as well as other stakeholders, have placed in us. The integrity and transparency of our business processes are one of our highest priorities.

It is, therefore, essential that the BARTEC Group is made aware of serious misconduct.

The compliance whistleblowing system operated by Safecall is a secure channel for reporting possible violations. The hotline is available 24 hours a day, 7 days a week, 365 days a year, and reports can be made in a number of different languages. Reports can be made online or by phone, and callers who wish to do so may remain anonymous.

The Safecall whistleblowing hotline is available to BARTEC employees and executives, customers, suppliers, and other company stakeholders. The hotline is operated by an independent service provider, and data is stored in accordance with legal provisions on protected servers. It is important to note that all reports received via Safecall are handled exclusively by the BARTEC Group’s Compliance Office.

BARTEC internal whistleblowers are protected by the EU Whistleblowing Directive. This prohibits BARTEC from penalizing whistleblowers who make reports in good faith and to the best of their knowledge. Please be aware that intentional reporting of false information is prohibited by law in many countries.

More information regarding submitting whistleblowing reports is available on the Safecall homepage.

Whistleblowing System FAQ

Why should I use the Whistleblowing service?

You may become aware of conduct that may cause harm to the BARTEC Group. By using the whistleblowing service to report potential misconduct, you may help BARTEC to identify issues in time to take action before any damage occurs. In doing so, you are making a vital contribution to the sustainable success of BARTEC and helping to secure jobs.

Safecall’s whistleblowing hotline may be used to report such practices as: unethical behavior, corruption, environmental issues, antitrust violations, fraud, or product compliance issues.

There are three main ways you can contact Safecall: via a free call, by email, or by sending a report via Safecall’s website.

When you contact Safecall by phone, you will be asked by the call handler to explain your concerns in as much detail as possible. During this time, the call handler will take notes and may ask questions. Once the call is complete, Safecall will send a written report to BARTEC’s Compliance Office. Alternatively, you can also send an email to the address listed below. In addition, you can also use the online form provided on the Safecall website, which is available in many languages.

Yes. You may make an anonymous report. Safecall does not record calls; instead, your report will be taken down manually.

The report is initially sent to the BARTEC Group’s Compliance Office. The Compliance Office investigates potential violations and takes appropriate measures to detect, remediate, and, if necessary, penalize the misconduct.

Regardless of which reporting channel you use, you will receive a confirmation of receipt within seven days of receiving your report. If you use Safecall or parallel reporting channels set up at the respective locations, the report will then be sent to the Compliance Office. The Compliance Office examines the possible breaches of rules and takes appropriate measures to uncover, remedy and, if necessary, punish the breaches of rules committed.

You will be informed of any follow-up measures planned or already taken and the reasons for these within three months of confirmation of receipt of the report at the latest. Follow-up measures may include, for example, the initiation of internal investigations, measures to rectify the problem, referral to other channels or procedures for reports, closure of the procedure due to lack of evidence or for other reasons, or referral to a competent authority.

The documentation created about the report is usually deleted three years after the procedure has been completed.

BARTEC employees are protected by the EU Whistleblowing Directive. Retaliation against a person who has, to the best of their knowledge, reported a potential violation is strictly prohibited. If, however, false or misleading information has been knowingly reported, consequences can be expected.

Phone: Free Hotline - find the phone numbers at the Safecall website 
Online: www.safecall.co.uk/report
email: bartec(at)safecall.co.uk

In addition, there are alternative external reporting processes to authorities, institutions, organisations or other agencies of the European Union. 

Alternative external reporting channels:

  • at the Federal Office of Justice (www.bundesjustizamt.de)
  • at the Federal Financial Supervisory Authority (www.bafin.de)
  • at the Federal Cartel Office (www.bundeskartellamt.de)
  • in the respective federal states 
  • the European Commission
  • the European Anti-Fraud Office
  • the European Maritime Safety Agency
  • the European Aviation Safety Agency
  • the European Securities and Markets Authority
  • the European Medicines Agency.

 

 

BARTEC Varnost d.o.o.

Slovenia

Karmen Drnovšek

E-Mail: karmen.drnovsek(at)bartec-varnost.si

Phone: +386 (0) 59 221 432

BARTEC Business Development & Project Management Office (BBC)

Slovenia

Martina Brinc

E-Mail: compliance_bbc(at)bartec.com

BARTEC F.N. s.r.l.

Italy

Raffaella Natarelli and Valentina Squara

E-Mail: whistleblowing(at)bartec-fn.com

Phone: +39 (0) 248474455 / +39 (0) 248474317

Fenex s.r.l.

Italy

Francesco Menotti and Meri Lorenzon

E-Mail: whistleblowing(at)fenex.biz

Phone: +39 (0) 481808263

BARTEC Benke GmbH, Gotteszell

Germany

Ingrid Schreiner

E-Mail: complianceGTZ(at)bartec.com

Phone: +49 (0) 9929 301211

BARTEC Benke GmbH, Reinbek

Germany

Henning Benecke

E-Mail: henning.benecke(at)bartec.com

Phone: +49 (0) 40 72703 212

BARTEC Vertrieb Deutschland GmbH (BVD)

Germany

Andrea Link-Schmidt

E-Mail: andrea.link-schmidt(at)bartec.com / compliance(at)bartec.com

Phone: +49 (0) 163 6597316

BARTEC GmbH

Germany

Andrea Link-Schmidt

E-Mail: andrea.link-schmidt(at)bartec.com / compliance(at)bartec.com

Phone: +49 (0) 163 6597316

Contact