Trusted Shops Compliance Policy

This policy describes organisational measures and regulations that are intended to ensure the lawful, responsible, mindful and sustainable actions of our company and its employees with regard to compliance with laws and guidelines.

1 Anti-Discrimination and Anti-Harassment Code of Conduct (CoC)

Objective

Trusted Shops is committed to a trustworthy work environment in which all individuals are treated with respect and dignity. Each individual has the right to work in a professional atmosphere that promotes equal employment opportunities and prohibits unlawful discriminatory practices, including harassment. Therefore, Trusted Shops expects that all relationships among persons in the office will be business-like and free of bias, prejudice and harassment.

Trusted Shops has developed this code of conduct, a behavioural guideline for every employee at Trusted Shops. Trusted Shops will make every reasonable effort to ensure that all concerned are familiar with this CoC and are aware that any complaint in violation of such policies will be investigated and resolved appropriately. Furthermore, in order to raise awareness and work on actions that promote diversity and inclusion, Trusted Shops has implemented the Diversity & Inclusion working group, which is managed by Marco Schmitz.

Fundamentals

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  • Non-discriminating treatment of all persons related to Trusted Shops
  • Rejection of child labour and forced labour
  • Encouragement of employees to openly speak out about in-house issues
  • Observing the law of all countries in which we operate

Individuals and Conduct Covered

This CoC applies to all applicants and employees, whether related to conduct engaged in by fellow employees or by someone not directly connected to Trusted Shops (e.g., an outside vendor, consultant or customer).

Conduct prohibited by these policies is unacceptable in the workplace and in any work-related setting outside the workplace, such as during business trips, business meetings and business-related social events.

Definition of discrimination

The unequal treatment of members of various groups on the basis of gender, race, color, religion, sex, sexual orientation, gender identity or expression, age, disability, economic background, marital status, citizenship, national origin, genetic information, or any other characteristic protected by law (hereinafter referred to as “Characteristics”). Common examples of discriminatory behavior are: Inappropriate verbal comments (e.g. “locker room talk”), offensive drawings / memes, the use of degrading language, unwelcome touching, comments about appearances, staring, generalizing about a group of people, especially in a negative way (e.g. women), references to stereotypes and alike.

Equal employment opportunity

It is the policy of Trusted Shops to ensure equal employment opportunity without discrimination or harassment on the basis of the abovementioned Characteristics. Trusted Shops prohibits any such discrimination or harassment.

Sexual harassment

Sexual harassment constitutes discrimination and is illegal under the law. For the purposes of this CoC, “sexual harassment” is defined as unwelcome sexual behavior that’s offensive, humiliating, or intimidating. It can be written, verbal, or physical, and can happen in person or online. People of any gender can be the victims of sexual harassment.

Depending on the circumstances, these behaviors may include:

  • Making conditions of employment or advancement dependent on sexual favors, either explicitly or implicitly.
  • Sexual jokes and innuendo
  • Verbal abuse of a sexual nature
  • Commentary about an individual’s body, sexual prowess, or sexual deficiencies
  • Unwanted touching or physical contact, leering, whistling
  • Unwelcome sexual advances
  • Insulting or obscene comments or gestures
  • Unwanted sexually explicit objects, photos, emails, or text messages
  • Other physical, verbal, or visual conduct of a sexual nature

Harassment

Harassment on the basis of any other protected characteristic is also strictly prohibited. Under this policy, harassment is verbal, written, or physical conduct that denigrates or shows hostility or aversion toward an individual because of their Characteristics, or that of their relatives, friends, or associates, and that: a) has the purpose or effect of creating an intimidating, hostile or offensive work environment, b) has the purpose or effect of unreasonably interfering with an individual’s work performance, or c) otherwise adversely affects an individual’s employment opportunities.

Harassing conduct includes epithets, slurs, or negative stereotyping; threatening, intimidating, or hostile acts; denigrating jokes; and written or graphic material that denigrates or shows hostility or aversion toward an individual or group that is placed on walls or elsewhere on the employer’s premises or circulated in the workplace, on company time or using company equipment by e-mail, phone (including voice messages), text messages, social networking sites or other means.

Reporting an Incident of Harassment, Discrimination, or Retaliation

Trusted Shops encourages reporting of all perceived incidents of discrimination, harassment, or retaliation, regardless of the offender’s identity or position. Individuals who have been the victim of such conduct should discuss their concerns with one of the listed contact persons, as specified in the complaint procedure described below. Any reported allegations of harassment, discrimination or retaliation will be investigated promptly. 

Hintbox – whistleblowing system

Hintboxis a web-based internal reportingchanneltoreportactualor potential violationsof European and national laws, the Compliance policy and other internal policies. The informationisprocessed in a fair, fast and protectedprocess.

If you wish, you can submit your report anonymously. Further information on how to deal with reports received can be found on the homepage of the whistleblowing system (trustedshops.hintbox.de).

Contact persons

If you rather wish talking to someone or use any other means of communication, please contact the following persons directly:

People Business Partner / People Manager

You can talk to your People Business Partner or your People Manager about any kind of discriminatory behavior you’ve witnessed or experienced. Your People Business Partner and People Manager will treat your reports seriously, justly, and promptly, and if something needs to be fixed, they will take action.

Trust Persons

The Trust Persons are three employees (male and female) who are elected every
two years by all Trusted Shops employees. They act as an alternative, independent point of contact for you whenever there is any kind of problem you need help with, including incidents of discrimination. You may also choose to contact the Trust Persons directly and individually via Hintbox.

Legal Basis

In Germany, the “Allgemeines Gleichbehandlungsgesetz” (General Equal Treatment Act) serves to enforce the principle of equal treatment. The aim of this law is to prevent or to eliminate discrimination on grounds of race or ethnicity, sex/gender, religion, disability, age, or sexual identity. The employer has to take measures to prevent discrimination. In case of discrimination, the employee has a right to complain, and is entitled to compensation.

No retaliation

Trusted Shops encourages reporting of all perceived incidents of discrimination or harassment. It is the policy of Trusted Shops to promptly and thoroughly investigate such reports. Trusted Shops prohibits retaliation against any individual who reports discrimination or harassment or participates in an investigation of such reports. On the contrary: such reporting fosters an open and tolerant corporate culture under the “Spirit of Trust”.

2 Complaint procedure and responsive actions

Any reported allegations of harassment, discrimination or retaliation will be investigated promptly. We guarantee the greatest possible protection for whistleblowers and do not take any measures to identify anonymous whistleblowers. Investigations are conducted with the utmost confidentiality. 

The investigation may include individual interviews with the parties involved and, where necessary, with individuals who may have observed the alleged conduct or may have other relevant knowledge.

Trusted Shops will maintain confidentiality throughout the investigatory process to the extent consistent with adequate investigation and appropriate corrective action.

Responsive actions

Misconduct constituting an infringement of this compliance policy will be dealt with appropriately. Responsive action may include, for example, training, referral to counseling or disciplinary action such as a warning, reprimand, withholding of a promotion or pay increase, reassignment, or termination, as Trusted Shops believes appropriate under the circumstances.

If a party to a complaint does not agree with its resolution, that party may appeal to Trusted Shop’s executive directors or the head of the People department.

False and malicious complaints of harassment, discrimination or retaliation (as opposed to complaints that, even if erroneous, are made in good faith) may be the subject of appropriate disciplinary action.

3 Dealing with business partners and third parties

We do not bribe and do not accept bribes!

In competition, we focus on performance, customer orientation, and the quality of our products and services, not on illegal or ethically questionable behaviour. We therefore reject corrupt and other illegal behaviour and do not tolerate such behaviour. We expect from our managers, employees, and business partners (e.g. service providers, consultants, suppliers), not to engage in corrupt practices and to comply with all applicable laws, regardless of the countries in which they operate.

In our dealings with political parties, domestic and foreign authorities, and public officials, we pay particular attention to business conduct with integrity. We do not grant any payments, benefits, or other advantages of monetary value to public officials, employees in the public sector, or employees of a publicly owned company in order to obtain orders or benefits for us. This prohibition also applies to conduct abroad, regardless of what is considered customary there. Nor do we make improper payments on specific business deals with private companies. Even the mere appearance of influence must be avoided.

Invitations, gifts, and other personal benefits

Invitations (e.g. invitations to restaurants or sporting events, food and beverages at events) may only be granted if their total value and the specific circumstances do not give the impression that the recipient of the benefit is expected to behave in a certain way in return.

Whether this is the case depends on the specific circumstances of the individual case, in particular the following factors:

  • Value of the advantage and frequency with which advantages are granted
  • Position of the recipient within their company
  • Social appropriateness

Benefits must never be granted secretly. Invitations or gifts must always be sent to the recipient’s office address, not to the recipient’s home address. Under no circumstances may cash or cash equivalents (e.g. vouchers) be given away. Permissible are gifts and benefits worth up to 35 euros per year and business partner (tax-deductible); gifts in excess of this amount must be approved by the management.

We apply the same care when we are offered an invitation or gift. We only accept invitations from business partners and customers to meals or events if they are they are extended voluntarily, serve a business purpose, do not take place unreasonably frequently, and the hospitality is commensurate with the occasion. We may accept promotional and occasional gifts voluntarily given by business partners and customers within a reasonable value and within reasonable limits. We use a guideline value of 35 euros as a basis for our assessment.

In case of doubt as to the appropriateness of gifts, gratuities or invitations, we consult with the Corporate Legal Team or the Executive Board. We disclose and document the receipt of gifts or gratuities or participation in meals or events if they exceed the guideline value of 35 euros (per year and partner). Reporting obligations based on other legal provisions (e.g. self-taxation of non-cash benefits) remain unaffected.

Stricter regulations for contacts with public officials

The term “public official” includes, at all levels, the representatives or employees of public authorities or other public bodies, agencies, or legal entities, as well as officials or employees of state-owned enterprises and public international organisations (civil servants, elected officials, soldiers, and other holders of public office).

The anti-corruption laws of many states contain strict provisions with respect to domestic and foreign public officials. The granting of personal benefits to public officials is prohibited, even if the benefits are of little value and would be acceptable if granted to employees of a private company. We must act prudently when granting a personal benefit to a public official and verify that the public official is legally permitted to accept it. In critical cases, we consult with management.

Relationships with service providers

Project-related service providers

In the case of service providers involved in the sale or marketing of our services (sales partners, consultants of an economic, technical or other nature), it must be ensured through appropriate documentation that there is no suspicion of corruption. A written agreement is required. This agreement must clearly and precisely define the remuneration of the service provider. This means that the remuneration received by the service provider must be precisely documented in figures or percentages by the time the order is received by Trusted Shops at the latest.

Duty to inform service providers and report violations

In contacts with service providers, our employees must always make it clear that we act in compliance with the applicable law, that we will not tolerate corrupt or otherwise unlawful conduct, and that we will terminate our relationship with a service provider in the event of corruption or other unlawful behaviour of the service provider. If there are indications of corrupt behaviour or other serious violations of the law by a service provider, employees must inform the Corporate Legal Team.

Invoicing customers, payments to customers, employees, suppliers or representatives of other companies

We issue invoices for the provision of our services with a time reference to the provision.

We do not make unauthorised payments to employees or agents of other companies, either directly or through service providers.

Payments we initiate for goods and services received will only be made directly to the relevant contractual partner, unless there are legally valid assignment agreements or compulsory collections.

Competition and antitrust law

We comply with the rules of fair competition. We do not engage in illegal and/or criminal practices, such as unlawful bid rigging that excludes, restricts, or distorts competition. We do not illegally obtain information relevant to competition or disseminate false information about a competitor, its products or services.

We do not engage in discussions or even detailed discussions on pricing and calculation, position in the respective national market, distribution structure, dealer network, etc. with competing members of the company. Even among supposedly friendly company members who do not appear to be in competition with each other, such a discussion may nevertheless be regarded as unlawful price fixing. In addition, confidentiality obligations under the employment contract may also be violated.

Donations

Donations and sponsorships are permitted within the framework of tax law and are approved by the management.

Trade Controls / Export Controls

We comply with all export control and customs laws.

Business relations with suppliers

We work to ensure that our business partners follow the same principles:

  • Compliance with all applicable laws
  • The renunciation of corruption
  • Respect for the human rights of employees
  • Compliance with laws against child labour
  • Taking responsibility for the health and safety of their employees
  • The observance of national laws and international standards on environmental protection

All customers, contractors and suppliers working with Trusted Shops must adhere to our Modern Slavery Code of Conduct.

4 Avoiding Conflicts of Interest – New Employees

Duty of loyalty

We expect our employees to be loyal to the company. Employees must make business decisions in the best interests of the Trusted Shops group of companies and not on the basis of personal interests. The taking up of secondary employment for remuneration requires approval. In particular, any involvement, consultancy, representation, or other activity with another company or for another company in the same or a similar industry is not permitted.

Political neutrality

In order to maintain the reputation of the Trusted Shops group of companies, we commit our employees to political neutrality in their external activities in their function for Trusted Shops. This equally applies to external activities in which you act as a Trusted Shops representative.

The process for newly hired employees ensures that they receive a copy of these compliance guidelines.

5 Dealing with company equipment

Each employee has a duty to use company property and assets in an expedient, economical, and responsible manner in all respects.

6 Handling of information

Confidentiality

Company and business secrets must be treated confidentially.

This also applies to other information in which the Trusted Shops group of companies, our contractual partners, and customers have an interest. All employees are expressly obliged to maintain confidentiality as part of their employment contract. This obligation continues after termination of the employment relationship.

The department and team leaders ensure compliance with the following rules in their area of responsibility:

  • Confidentiality agreements with third parties (including service providers, partners, suppliers, customers).
  • Confidentiality agreements are concluded with third parties who (potentially) gain access to confidential information of the Trusted Shops group of companies before the start of the cooperation.
  • The templates published by the Corporate Legal Team will be used.
  • If the contractual partner insists on its own template, this must first be forwarded to the Corporate Legal Team for review.

Data protection and security and protection of business secrets

The protection of privacy in the use of personal data and the security of business data shall be ensured in all business processes, taking into account legal requirements. Confidential information, official documents, and data carriers must be protected from access by third parties.

The department and team heads shall ensure compliance with the following rules in their area of responsibility.

The basic data protection obligations at the workplace:

  • Only clearly authorised persons within the company may provide verbal or written information on confidential data (of employees, customers, business partners, etc.).
  • Ensure that no one can view sensitive documents who is not authorised to do so or for whom there is no business need to do so (“need-to-know” principle).
  • Compliance with the “Data Protection at Work” policy and all internal data protection policies and instructions.
  • BYOD policy

When working on the move:

  • Those who use public transport and work on the move must ensure that fellow travellers do not gain insight into sensitive data (use privacy screens).
  • When using a notebook, tablet, or smartphone, always encrypt the hard drive and activate the lock function.
  • USB sticks can easily be lost, so confidential files on mobile data carriers should always be encrypted.
  • For security reasons, WLAN should only be switched on when it is actually being used.

7 Environment, safety and health

Environmental protection and technical safety

We comply with environmental protection regulations and standards, and use natural resources responsibly.

Occupational safety

Preventing accidents and protecting against work-related health hazards is part of the company’s duty of care, with each individual sharing responsibility towards employees and colleagues. All employees are obliged to participate in an annual training course on occupational safety.


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