Code of Conduc
Dear colleagues, Naumann Distribution GmbH maintains a corporate culture based on business ethics, integrity, and legal compliance.
Our reputation with customers, suppliers, service providers, and competitors is the foundation for our shared and sustainable success. Every day, we must reassess and decide whether our behavior is correct or not. In a global world characterized by increasingly complex legal regulations, informed and responsible business conduct is becoming increasingly demanding. At Naumann Distribution GmbH, we work together responsibly as a team, within modern and agile structures. This demands a high level of commitment and personal integrity from all of us. Our actions are perceived internally and externally, and we must be aware of this at all times.
It is our central concern that all employees at Naumann Distribution GmbH comply with the national and respective laws of the countries in which they operate.
Ethical conduct and compliance with the legal regulations applicable to our company and to activities in and related to our company must be observed at all times.
Our Code of Conduct and its guidelines are binding for all employees, regardless of their position, and for everyone who works with Naumann Distribution GmbH.
Violations of the provisions of our Code of Conduct and/or laws or other legal regulations constitute breaches of duty. These can cause serious economic damage and damage the reputation of Naumann Distribution GmbH in the long term. All employees should ensure that such violations do not occur and, in case of doubt, can contact us using the reporting channel below.
Thank you for your support!
The Management
Bernd Naumann Michael Karrasch
Validity, Compliance, and Implementation of the Code of Conduct
Whistleblower System
As a company, Naumann Distribution GmbH takes reports and indications of potential violations very seriously and investigates them for clarification. Employees and other whistleblowers (e.g., contractors, customers, or suppliers) are hereby encouraged to report violations or suspected violations of applicable laws, internal policies, or regulations via the designated whistleblower procedure. This ensures that such matters can be clarified – in the interests of the whistleblowers, all potentially affected persons, and the company itself.
- This procedure is intended to provide whistleblowers with a safe and secure way to report ethical concerns and violations of laws, internal policies, or regulations to the company.
- Reports can be made by email, telephone, or in person, and, of course, anonymously upon request.
- Protection from Discrimination: Employees who report to the best of their knowledge in accordance with the Whistleblower Protection Act are protected from (employment) legal or professional discrimination.
- Confidentiality: The identity of the whistleblower will be treated confidentially. This does not apply if Naumann Distribution GmbH is expressly required to do so by law or by the competent authorities. In such a case, only the persons investigating the report will be informed of the identity of the reporting person.
The whistleblower will not suffer any disadvantage by using the whistleblower procedure, as long as they do not themselves violate legal regulations. Reports submitted through our whistleblower system should be made to the best of their knowledge, whether anonymously or by name.
If employees make a report that is not substantiated by the subsequent investigation, Naumann Distribution GmbH will not take any disciplinary or other measures against them, unless they have intentionally or maliciously made inaccurate reports.
Our reporting channels:
To the management's email addresses B.Naumann@Naumann-distribution.com or M.Karrasch@Naumann-Distribution.com. By letter to the management.
As soon as a report is received, a corresponding confirmation will be sent. The Compliance Team will then review the report. Follow-up questions may be raised because additional information is required.
For this reason, the whistleblower should keep an eye on their chosen communication method. In the case of an anonymous report, all necessary information should be provided so that an investigation can be carried out.
Violations and Sanctions
Under no circumstances will violations of applicable law or the Code of Conduct be tolerated by employees, regardless of their position, or by our company's business partners. Violations of applicable legal regulations and the provisions of this Code of Conduct may result in appropriate disciplinary measures, up to and including termination of employment.
Dealing with Colleagues
Zero Tolerance for Discrimination:
Naumann Distribution GmbH does not tolerate any discrimination based on race, gender, age, nationality, ethnic origin, skin color, political opinion, sexual orientation, religious beliefs, social origin, physical constitution, or other personal characteristics. This applies in particular to dealings with employees and business partners, as well as to the hiring, promotion, or dismissal of employees.
Zero Tolerance for Harassment:
Naumann Distribution GmbH does not tolerate any form of personal harassment – this includes, in particular, bullying, unwanted sexual advances, unwanted physical contact, indecent offers, or a work environment marred by offensive jokes, remarks, and degrading behavior. Our employees always treat each other and our suppliers, service providers, and customers with respect.
Behavior towards Business Partners
Avoiding Conflicts of Interest:
Conflicts of interest can arise when one's own private interests interfere or appear to interfere with the interests of Naumann Distribution GmbH, work duties, or the interests of Naumann Distribution GmbH. All employees conduct themselves fairly in their work environment and avoid any conflict between their personal interests and the business interests of Naumann Distribution GmbH or the interests of our customers.
We therefore ask that you always ensure that your own position and/or your own opportunities at Naumann Distribution GmbH are never exploited or used for personal gain. To avoid potential conflicts of interest from the outset, the following assignments and activities may only be undertaken if they have been previously approved in writing or text form by management or their representatives:
- Assignments to related parties (e.g., partners, spouses, relatives, friends) or to their companies.
- Assignments from companies in which related parties work.
- Secondary employment for competing companies.
- Secondary employment for business partners or related parties.
Zero tolerance for active and passive corruption:
Naumann Distribution GmbH maintains the highest standards for preventing and combating all forms of corruption and unconditionally adheres to applicable anti-corruption laws.
Our employees will never offer, promise, or grant benefits to contacts and decision-makers at our business partners or their relatives in order to influence behavior or business decisions favorable to Naumann Distribution GmbH. Likewise, our employees will never offer, promise, or grant such personal benefits to themselves or third parties if doing so could create, or even create, the impression that our employees are or are being influenced in business-relevant decisions at and for Naumann Distribution GmbH. We are not for sale and will always actively counter any other impression.
All business transactions must be fully and accurately documented in accordance with legal requirements.
Handling Gifts, Invitations, and Entertainment:
Naumann Distribution GmbH procures and distributes goods and services based on high product and service quality, especially in customer support. The impression must not be created that our decisions regarding the procurement and provision of goods and services were made because we or individual employees have given or received gifts, perks, entertainment, or other benefits, or have been promised such gifts, perks, entertainment, or other benefits, the purpose or result of which was or was intended to be unfair preferential treatment.
Donations/Sponsorship:
Decisions regarding donations or sponsorships are solely the responsibility of management. If our employees are personally approached with donation or sponsorship requests, they should point out that they are not authorized to make decisions regarding these matters at Naumann Distribution GmbH.
Money Laundering Prevention:
Naumann Distribution GmbH has implemented risk-appropriate precautionary measures to prevent money laundering and the financing of international terrorism in accordance with legal provisions and regulatory requirements. Money laundering is the process by which funds from illicit sources are channeled into legitimate financial channels or legitimate funds are diverted for illicit purposes.
To prevent Naumann Distribution GmbH from inadvertently becoming involved in money laundering activities, the legal regulations, and in particular the principle of clear business partner identification, must be followed. This requires the identity of each customer or business partner to be established at all times. If even the slightest appearance of illegality remains, the transaction must be rejected.
Antitrust Directives and Competition Law:
Antitrust laws and competition law serve to promote a fair and open market by prohibiting certain agreements and the sharing of information with competitors. Prohibited agreements include, for example, price fixing or bid-rigging, territorial or customer allocations, boycotts of customers or suppliers, and tying agreements. Naumann Distribution GmbH does not participate in illegal agreements and practices that restrict competition, in particular agreements on prices, terms, and conditions, and market allocation with competitors. Before employees deviate from standard contracts or any procedures stipulated in cooperation agreements, they must clarify with management that this will not have any impermissible consequences under competition law.
When contacting competitors and business partners, employees must never discuss internal matters at Naumann Distribution GmbH, such as prices and sales or financing conditions, costs, market overviews, organizational processes, or other confidential information from which competitors or business partners could gain a competitive advantage, without prior consultation with management.
Conduct within and towards the company
Compliance with data protection:
Naumann Distribution GmbH collects, processes, and uses personal data only if it is necessary for specified, clear, and legitimate purposes.
Naumann Distribution GmbH protects the personal data of its employees and business partners entrusted and processed in connection with its business activities, as well as the privacy of individuals, through careful and responsible handling and the necessary technical and organizational measures against unauthorized use. Within the scope of their duties at Naumann Distribution GmbH, all employees are obligated and responsible for treating such personal data confidentially and responsibly in all business processes. Personal data may only be processed in accordance with the applicable data protection regulations, for the intended purposes, and by the authorized persons.
Obligations of secrecy and confidentiality:
All employees of Naumann Distribution GmbH are obligated to maintain confidentiality regarding internal company processes and data, trade and business secrets, and all other matters classified by management as confidential or requiring confidentiality. Business documents must be protected from unauthorized access by internal and external persons.
Occupational safety and health:
In the interest of the health and safety of all employees and customers, all employees of Naumann Distribution GmbH comply with all applicable laws, regulations, and standards regarding occupational safety. They continually review the rules applicable in their areas of responsibility and work. Routine often leads to the disregard of guidelines designed to protect employees. Identified potential sources of danger should be reported immediately via the established reporting channels. We will investigate these and, where necessary, resolve them immediately.
Company Property:
Naumann Distribution GmbH is committed to protecting employees, company property, and property entrusted to it by customers and business partners from loss, theft, or misuse. Naumann Distribution GmbH's IT facilities and systems (email, internet, and other communication systems) are used only for legitimate business purposes. Private use is prohibited. Please note that emails are also business documents that must be retained and may be used as evidence in court or otherwise made public. Naumann Distribution GmbH may access employees' emails and internet activities, to the extent permitted by law and if necessary for security or operational reasons. Naumann Distribution GmbH's IT should therefore be used responsibly and in compliance with regulations. The use of IT facilities and systems for private use is prohibited for all employees, both at work and when working from home or remotely.
Tax Compliance:
Because Naumann Distribution GmbH operates in numerous countries, we are subject to the supervision of various tax authorities. Adherence to and compliance with all tax-related procedures and tax laws and regulations is of central importance to Naumann Distribution GmbH.
Foreign Trade and Export Control / Trade Controls
Foreign Trade:
Employees working for Naumann Distribution GmbH are obligated to comply with applicable national and international laws and regulations at all times. Naumann Distribution GmbH imposes the same requirements for integrity and lawful conduct on all suppliers, customers, and service providers.
Export Control / Trade Controls:
Naumann Distribution GmbH distributes goods and services to a wide variety of countries and always observes the relevant national and international export control regulations. All employees at Naumann Distribution GmbH are obligated to comply with all applicable import and export control regulations, all customs regulations, trade controls, and any embargoes within the scope of and in connection with their work for Naumann Distribution GmbH.
U.S. Foreign Trade:
Products from U.S. companies, such as software and services, are subject to U.S. export controls in addition to country-specific trade requirements. They may not be delivered to sanctioned or debarred persons or countries without U.S. government approval.
It is prohibited to cooperate with companies or individuals who violate applicable embargoes, boycotts, or other regulations of the United States or other countries.