ElringKlinger AG

Code of Conduct

We believe that long-term success is founded on the trust of customers and shareholders in our expertise, our abilities as an innovator and, not least, our integrity. Earning that trust – which is reflected in the reputation of our company – largely depends on having a workforce that is fully committed to our values and objectives and to discharging their various responsibilities accordingly. This code of conduct, which provides guidance and sets the benchmark for staff behavior, is binding on all employees of the ElringKlinger Group.

Compliance with laws and guidelines

We expect all employees of the ElringKlinger Group to observe applicable legal regulations and company guidelines. In particular, all managerial staff are expected to set an appropriate example.

Where a staff member has questions or concerns regarding compliance with specific legal regulations or other provisions relating to conduct within their field of responsibility, the employee must contact their immediate manager or the relevant department for clarification. Staff members can also address questions to the responsible compliance officer.


We expect all employees to refrain from and refuse to tolerate corrupt or similarly unlawful conduct within their sphere of activity. In this regard, staff of public authorities and business partner companies may not be offered or guaranteed any advantages or financial incentives that would incite them to engage in unlawful or dishonest actions. Where an employee is offered incentives of this kind, he must inform his superior without delay in all cases.

Since corrupt conduct can have very serious implications for the entire ElringKlinger Group, it can never be justified by any business advantage.

Conflicts of interest

We expect all employees to make business decisions in the interests of the company and to act accordingly. Decisions and actions taken in the interests of the company must not be influenced by personal motivations, relationships or benefits. Conflicts of interest of this kind can arise in particular where an employee establishes a business connection with a dependant, relative or close friend or enters into business transactions in which such persons are closely involved. Business relationships with such persons must be avoided; however, managers may allow justified exceptions to the rule on business relationships where the circumstances giving rise to a possible conflict of interest are disclosed in advance.

In all cases, secondary employment must be declared and approved under the terms of agreed employment contracts. Secondary employment with a competitor of the ElringKlinger Group cannot be approved under any circumstances. Shareholdings or ownership interests amounting to more than 5% of corporate capital in respect of a competitor, client or supplier company must be declared to the relevant human resources department.

Fair competition

We expect all employees to observe regulations on competition law within their fields of responsibility. Agreements with competitors that violate anti-trust law (for example on prices or other terms and conditions) are prohibited. Where an employee is approached with the aim of persuading that employee to enter into an agreement that breaches anti-trust law, he must inform his manager and the compliance officer without delay.

We are committed to fair competition; staff must therefore refrain from unfair conduct. Suppliers are contracted in line with clear and objective criteria, and arbitrary reasons play no part in the selection of a supplier.

Insider dealing

We expect all staff in possession of relevant insider knowledge to refrain from using that knowledge to deal in shares of ElringKlinger AG. Since shares in ElringKlinger AG are registered for trading on stock exchanges in Germany, the legal regulations governing insider dealing must be observed. This applies to all staff of the ElringKlinger Group who, because of their position or role within the company, possess specific knowledge of circumstances affecting the ElringKlinger Group which, if made public, could influence the share price. The purchase or sale of shares in ElringKlinger AG immediately after the publication of annual financial statements, quarterly reports or semi-annual reports is acceptable. In cases of doubt, staff may contact the compliance officer.

Gifts (and other benefits), invitations and donations

All staff are expected to refrain from giving or accepting any gifts or other benefits in the course of normal business transactions that are inappropriate or improper, taking local customs and practices into consideration. In no event may financial benefits be linked to claims for or guarantees of counterperformance.

The aforementioned principles apply accordingly to invitations to business lunches or other events; in all cases, such events must take place for business reasons in a routine business context. Invitations to events that violate laws or company guidelines or which may be generally regarded as dishonest, inappropriate, improper or immoral may not be made or accepted.

Employees are prohibited from accepting or offering benefits or invitations wherever binding dependency or dishonesty may be suspected. In cases of doubt, the acceptance of benefits or granting of invitations must be agreed and approved in advance by the immediate superior (and the compliance officer if necessary). In any event, an employee must inform his manager if he is offered inappropriate benefits or invitations.

All donations to social projects, associations, political parties, other federations or individuals must be agreed with the management of the respective company; where donations exceed an amount defined in specific cases, the authorization of the Management Board of the ElringKlinger Group is required. Donations may never be granted with the aim of attaining a direct commercial advantage.

Traveling expenses, allowances and other business-related expenses

We expect all employees to make a strict distinction between private expenses and business expenses. Business-related expenses must be calculated according to the relevant company guidelines; in this regard, we also expect employees to utilize resources reasonably and sparingly.

Data protection and confidentiality

We expect all employees to refrain from passing any confidential data, information on processes and information on the plans of the ElringKlinger Group, its customers and suppliers to unauthorized third parties; moreover, we expect all employees to treat such data and information in strict confidence and to utilize this for business purposes only. The same applies to personal data on employees of the ElringKlinger Group; to that end, the relevant data protection requirements must be observed.

Zero tolerance of discrimination

Employees may not discriminate against anyone on the grounds of their gender, skin color, age, nationality, religious affiliation, social background, disability or sexual orientation. As a global organization, we believe that successful working relationships are based on mutual respect between individuals. Professional development within the ElringKlinger Group is based on the performance, skills and personal aptitudes of individuals.

Safety at work, health and environmental protection

We expect all employees to play their part in ensuring a safe and orderly working environment and to comply with the applicable provisions governing workplace safety, health and environmental protection. All staff are required to utilize existing resources economically and sparingly. Admissible environmental harm must be minimized or avoided altogether wherever possible.

Support, monitoring and sanctions

We take steps to ensure all employees receive adequate support in upholding the stated principles of conduct within their fields of responsibility. All managers are required to make every effort to support their staff, take note of suggestions, clarify specific questions regarding the code of conduct and introduce measures as necessary. Employees may also contact the compliance office for their region or the ElringKlinger Group itself at any time; confidentiality and anonymity are guaranteed where a member of staff wishes to do so.

Compliance with the relevant provisions, guidelines and with this code of conduct is critical to the ElringKlinger Group and is therefore regularly monitored. Breaches on the part of individuals can lead to serious and far-reaching consequences for the entire company, ranging from damage to the reputation of the ElringKlinger Group to significant financial penalties and fines. In certain cases, members of staff responsible for such outcomes may be held personally liable. In the interests of the company as a whole, we will not tolerate violations of the code of conduct. Depending on the circumstances of each case, transgressions will therefore result in sanctions under labor law or even criminal law.

Compliance organization at ElringKlinger

Within the ElringKlinger Group, responsibility for issues connected with the organization of compliance lies with the Chief Compliance Officer, who reports directly to the Chief Executive Officer on all compliance matters. Compliance Organization focuses on defining compulsory regulations and monitoring their implementation.

The Chief Compliance Officer is Dr. Christof Dietborn; responsible Compliance Officers have also been appointed for all regions in which ElringKlinger operates. All staff members may approach the Chief Compliance Officer and the various regional Compliance Officers with questions, and especially those relating to the Code of Conduct, which is binding on all employees of the ElringKlinger Group; the same applies to all other guidelines and directives connected with compliance