Compliance Guidelines of the HÖRMANN Group

Strict compliance with the law, legislation and the regulations laid down by the HÖRMANN Group and the individual group companies for their employees form the basis for the employees’ actions. Fair, correct, and respectful behavior when interacting with colleagues, customers, suppliers and all other business partners lays the foundation for cooperation conducted in a spirit of mutual trust. The detailed provisions are set out in additional binding regulations.

The HÖRMANN Group is aware of its corporate responsibility to its employees, customers and business partners. This also includes a responsibility to society and its underlying principles. The HÖRMANN Group and its employees respect the personal dignity of every individual and do not tolerate any discrimination, harassment or bullying in the company’s activities around the world. Discrimination on account of race or ethnic origin, gender, gender identity or sexual orientation, religion or belief, disability or age is not tolerated and is remedied immediately where necessary.

The welfare of our employees is of great importance to us. We therefore implement health and safety measures that ensure their physical and mental well-being. Every employee plays a crucial role in implementing these measures and is required to play an active role in workplace safety, comply with all relevant regulations, rules and work instructions and report potential hazards in order to continuously improve occupational safety. The separate regulations in each of the group companies apply in this regard.

The HÖRMANN Group is aware of the scarcity of resources and is guided by the principles of sustainability. We strive to use resources responsibly and promote environmentally friendly practices in order to secure the quality of life for future generations. Every employee is called upon to play an active role in the implementation of sustainable measures.

In working for the HÖRMANN Group, employees are required to protect the interests of the Group. When performing their work, they are required to avoid conflicts between their private or personal interests and the interests of the HÖRMANN Group. To avoid potential conflicts of interest, employees must separate their private interests from the interests of the company. Decisions may not be influenced by private interests or personal relationships (directly or indirectly or via related parties). If there is a possibility that a conflict of this kind may arise, employees are required to inform their supervisor or the compliance officer immediately.

Good business relationships with customers, suppliers and even competitors are a prerequisite for business success. Managing these business relationships, however, must never cross the line into undue influence: The use of corruption in any form to achieve business objectives is prohibited. Corruption occurs, among other things, in the form of active and passive bribery of public officials, such as civil servants, as well as through the acceptance or granting of advantages from or to non-public officials. Corruption in its various forms is punishable by law in Germany and in almost every country around the world. The HÖRMANN Group does not tolerate corruption or bribery in its global activities. Accordingly, no employee of the HÖRMANN Group may offer or procure any undue advantages. No employee of the HÖRMANN Group may demand or accept undue advantages.

This prohibition of corruption applies in relation to German and foreign public officials as well as to business partners and other companies in the course of business. If employees become aware of such actions, they shall immediately inform their supervisor or the compliance officer and assist in clarifying the circumstances and documenting the incident. It should be noted that benefits in the form of gifts, invitations to hospitality, events, donations and sponsorship can also constitute an undue advantage. Benefits that could potentially influence business decisions made by partners can already be interpreted as corruption. Even the impression of potential influence must be avoided. Every employee who accepts or grants invitations or gifts shall comply with the relevant internal processes in order to ensure that they provide the necessary transparency and thus also that the correct tax treatment is applied.

With regard to its cooperation with business partners and the associated risks, the HÖRMANN Group has established its own process for screening, approving and documenting third parties that is specifically tailored to the company and that serves as a binding standard for all companies in the HÖRMANN Group. All employees of the HÖRMANN Group are required to adhere to the relevant processes and to ensure that the applicable “business partner compliance screening” is carried out before commissioning or entering into a contractual relationship with these third parties.

Freedom of competition is protected in Germany and in most countries around the world by strict competition and antitrust laws. All employees are prohibited in particular from entering into agreements and concerted practices between competitors that have the object or effect of preventing or restricting competition. Anti-competitive agreements in tenders may be punishable by long prison sentences. Abusing a dominant market position is also prohibited. Any agreement with competitors of the HÖRMANN Group that affects competition (for example, regarding prices, estimates, planning or other internal company matters) could be relevant in this context.

Giving preferential treatment to a supplier or service provider without verifiable and objectively justifiable reasons is neither permitted nor tolerated. Contracts are awarded on the basis of the business model of the HÖRMANN Group company in question, which must set clear regulations for this purpose within the framework of the applicable legislation. If an employee is in any doubt or has other questions, they can contact the compliance officer.

The HÖRMANN Group ensures compliance with all provisions governing the export of goods, services and information in accordance with the applicable statutory export control and customs regulations. Employees who are entrusted with the import, export or transfer of goods, services or information are required to be familiar with and comply with the legal provisions governing foreign trade in order to ensure that international trade proceeds without disruption and in compliance with the rules.

The HÖRMANN Group ensures compliance with the legal prohibitions on money laundering. Money laundering means that the origin of illegally obtained money or other assets (e.g. from terrorism, drug trafficking and other criminal activities) is disguised by injecting it into the legal economy, thereby creating the appearance of legality. We do not wish to be involved in money laundering activities either directly or indirectly, so we carefully screen business partners before working with them. If there are any doubts about whether financial transactions are permitted, every employee of the HÖRMANN Group is required to call in the relevant management immediately.

Every employee entrusted with company property belonging to or controlled by the HÖRMANN Group is responsible for the careful use, protection and management of these assets. This includes both tangible and intangible assets (including intellectual property rights).

Employees must protect confidential company information during their employment and after it has ended in accordance with the applicable laws and taking into account legal or regulatory disclosure requirements. All employees must comply with the applicable legal and company regulations on the protection of personal data and on data and information security.

The protection of personal data is a top priority for the HÖRMANN Group. We undertake to comply with all legal requirements regarding data protection, in particular the provisions of the General Data Protection Regulation (GDPR) and the Bundesdatenschutzgesetz (BDSG – Federal Data Protection Act). We process personal data exclusively in a lawful and transparent manner and for specific purposes.

Every employee is required to exercise the utmost care when collecting, processing and using personal data and to maintain the confidentiality and integrity of the data. Personal data will be disclosed to third parties only if there is a legal basis for doing so or if the data subject has given their express consent.

Violations of data protection regulations can have significant legal and economic consequences. If you have any uncertainties or questions about the handling of personal data, please consult the company’s data protection coordinator immediately.

The HÖRMANN Group is required to report accurately to employees, customers, business partners, suppliers, the public and the regulatory authorities and is aware of its responsibility to maintain complete, accurate and true business records and documentation, including financial statements, quality reports, time sheets and expense reports. The requirement to provide accurate information also applies to travel expense reports and other expense reports.

The employees of the HÖRMANN Group are required to ensure full compliance with these principles. The above-mentioned documents shall be prepared promptly and in accordance with applicable law and generally accepted accounting principles.