Code of Conduct for All Employees of the Meyer Logistics Group
Foreword
Mutual trust, honesty and respect, both internally and externally, are fundamental values firmly embedded in our company. These values encompass not only compliance with applicable rules and laws but also the personal attitude and commitment of all employees, whose collective efforts are essential to the company’s success. It is precisely this attitude that we seek to promote through this Code of Conduct, thereby documenting the fundamental principles and rules governing ethical business conduct.
At the same time, we require strict compliance with all applicable national and international rules and laws and seek to make this commitment transparent to our employees, customers, suppliers and other business partners.
The following Code of Conduct sets out these principles. Its purpose is to prevent situations that could call into question the integrity of our conduct or undermine trust in our services.
Building Trust Through Honest and Compliant Business Conduct – A Personal Responsibility and the Result of Collective Efforts
We can only achieve these objectives if everyone involved contributes. The Code of Conduct therefore establishes binding requirements for all employees.
Employees must comply with all laws and official regulations relevant to their working environment, as well as internal instructions and policies.
Employees are expected to act honestly and fairly in their professional environment and to avoid any conflict between their private interests and the business interests of our company or the interests of our customers.
All employees are expressly encouraged to contact the designated compliance representative or their supervisor if they become aware of conduct that does not comply with applicable rules. This can prevent minor issues from developing into serious problems. No employee who raises a concern in good faith need fear adverse consequences, even if the report subsequently proves to be unfounded. Reports may also be submitted anonymously.
Managers have a responsibility to lead by example. They are accountable for their own conduct and that of the employees within their area of responsibility, as well as for ensuring proper compliance with all procedures established to prevent reputational and legal risks.
Respectful Interaction – Prohibition of Discrimination – Development Based on Performance and Potential
Our success is also fundamentally based on treating one another with respect. We are willing to learn from mistakes and value open and honest communication. The key criteria for employee development are performance and potential.
We do not tolerate discrimination or harassment of any kind in the workplace, whether based on age, disability, origin, gender, political views, trade union activities, race, religion or sexual orientation.
Anti-Discrimination Policy
We are committed to creating a working environment free from discrimination and harassment. This policy aims to ensure equal treatment of all employees and that everyone is treated fairly and respectfully, regardless of gender, ethnic origin, religion, beliefs, disability, age, sexual identity or other personal characteristics.
Principles
We are committed to preventing discrimination in all its forms and promoting equal opportunities for all employees. We do not tolerate discrimination or harassment and actively promote a respectful and inclusive working environment.
Scope
This policy applies to all employees, regardless of their employment arrangements, including full-time, part-time and temporary agency workers, as well as interns and apprentices. It covers all aspects of employment, including recruitment, promotion, remuneration, professional development, dismissal and other employment-related decisions.
Definitions
Discrimination: Discrimination occurs when a person is disadvantaged because of certain characteristics, such as gender, ethnic origin, religion, beliefs, disability, age, sexual identity or other personal characteristics. Discrimination may be direct or indirect.
Harassment: Harassment is a form of discrimination and includes unwanted conduct that has the purpose or effect of violating a person’s dignity and creating an intimidating, hostile, degrading or humiliating environment. Examples include sexually offensive remarks, jokes or physical assaults.
Code of Conduct
All employees are required to treat their colleagues, supervisors, customers and business partners with respect and fairness. Every employee is responsible for contributing to a discrimination-free and inclusive working environment. Discriminatory behaviour or harassment of any kind will not be tolerated.
Measures to Prevent Discrimination
Training and Awareness: Regular training and awareness-raising activities are conducted to increase understanding of the importance of non-discrimination and diversity. All employees are informed of their rights and obligations and encouraged to recognise and report discriminatory behaviour.
Confidential Reporting Channels: We provide confidential reporting channels through which employees can report discrimination or harassment. These include the compliance hotline (telephone: 06175 4007 917, email: compliance@meyer-logistik.com) and personal discussions with the Compliance Officer or other trusted individuals.
Investigation and Action: All reports of discrimination or harassment are investigated promptly and thoroughly. We are committed to taking appropriate action to stop such incidents and ensure that affected individuals are protected. This may include disciplinary measures against those responsible and support measures for victims.
Support for Affected Individuals
Individuals affected by discrimination or harassment receive support from the Compliance Officer and other internal resources. This may include counselling, mediation or other measures to safeguard their well-being and safety.
Protection Against Retaliation
Employees who report discrimination or harassment are protected against retaliation. We do not tolerate any disadvantageous treatment of employees who submit complaints in good faith or participate in an investigation. Any form of retaliation against such employees will be subject to strict disciplinary action.
Responsibilities
All employees are responsible for complying with this Anti-Discrimination Policy and promoting a respectful working environment. Supervisors have a particular responsibility to lead by example and ensure that their teams understand and comply with this policy.
Review and Updates
This Anti-Discrimination Policy is reviewed regularly and updated as necessary to ensure that it continues to meet current requirements and the needs of the company.
Protection of Personal Data and Confidential Information – Requests for Information from Authorities
We strictly observe all regulations concerning the protection of personal data.
Confidential information and documents relating to customers, our company or employees must be appropriately protected against access by third parties and colleagues who are not involved.
Personal data may only be collected, processed or used where necessary and where an appropriate legal basis or the consent of the data subject exists. The use of personal data must be transparent to the individuals concerned. Their rights of access and rectification and, where applicable, their rights to object, restrict processing and obtain erasure must be respected.
Appropriate technical safeguards must be implemented to protect data and information against unauthorised access, in accordance with the current state of technology.
Our company has established additional policies on data protection and information security, to which explicit reference is made.
We cooperate with all competent public authorities and supervisory bodies. Any communication with such authorities must be conducted exclusively by employees authorised for this purpose.
Communication with Customers, Business Partners and the Public
All statements and reports must be complete, honest, accurate, timely and comprehensible, whether addressed to business partners, customers or the public.
This applies particularly to information and promotional materials concerning our products and services.
Information about our company, our services, our customers or business partners may only be communicated to business partners, customers or the public by duly authorised employees.
Social Media
Anyone participating in public discussions or posting on social media about matters relating to our company or our business partners should make it clear that they are acting in a personal capacity while remaining mindful of the interests of the company and its business partners. Please bear in mind that statements made in emails or on social media may be informal and spontaneous, but can nevertheless remain recorded and accessible to recipients or the online public for a long time.
Avoiding Conflicts of Interest Involving Customers and Business Partners
Our company seeks to establish sustainable business relationships with its customers and business partners for mutual benefit.
Every employee must therefore ensure that the interests of our customers are considered fairly. The interests of individual customers or business partners must not be prioritised to the detriment of other customers.
Customer Complaints
Customer complaints provide valuable information about opportunities to improve our business and, when handled appropriately, offer an opportunity to strengthen or restore customer relationships.
We ensure that all significant customer complaints are addressed promptly, fairly and transparently.
Personal Conflicts of Interest
Conflicts between employees’ personal interests and their professional duties or the interests of the company or our customers may damage the reputation of both the individuals concerned and the company as a whole.
Employees should therefore avoid such situations in the interests of both the company and themselves. The following rules apply:
- No secondary employment or activities that interfere with the time commitments arising from contractual employment obligations or adversely affect the company’s competitive interests. Secondary employment must be reported in writing to the employee’s supervisor and the Human Resources department in advance. Voluntary activities involving a limited time commitment do not need to be reported.
- No financial interests in companies that may be affected by the professional decisions of the employee or the company.
- The awarding of contracts to relatives, domestic partners or other closely associated persons of employees must, where known, be disclosed in advance to the employee’s supervisor and the Compliance department. This also applies to business transactions with companies in which relatives hold direct or indirect interests.
- No assumption of positions involving corporate responsibility (e.g. member of a governing body, managing director, executive board member, supervisory board member or advisory board member) with customers, business partners or competitors without prior approval from senior management following notification to the Compliance department.
In cases of doubt, the Compliance department should be consulted. The perception of third parties is decisive. Even the appearance of a personal conflict of interest can be damaging.
Gifts, Business Meals and Events
Gifts, business meals and events organised for informational, representative or entertainment purposes can be legitimate means of establishing and maintaining business relationships. However, they must never be used to obtain improper business advantages or be offered or accepted to an extent or in a manner that could call into question the professional independence and judgement of those involved.
Employees can protect themselves against misunderstandings by observing the following rules:
- Reasonable hospitality and invitations to meals directly related to business activities are generally acceptable.
- Promotional giveaways of nominal value are generally acceptable.
- Gifts with a market value of up to EUR 40 (indicative threshold) are generally acceptable, unless:
- they are offered shortly before the conclusion of contracts or in connection with negotiations,
- they are sent to a private address or presented in another non-transparent manner.
- Never accept cash or cash equivalents, such as cheques, gift vouchers or fuel vouchers.
- Do not accept invitations to representative events or events involving entertainment, whether predominantly or in part, unless:
- the invitation has been specifically assessed for customary business practice and appropriateness,
- representatives of the host are present,
- participation does not occur frequently, and
- travel and accommodation expenses are not paid by the inviting business partner.
In cases of doubt, the Compliance department must be consulted.
Particular caution is required when dealing with public officials. The applicable rules of the relevant public authority concerning gifts and invitations must be observed.
Donations and Sponsorship
Decisions regarding donations and sponsorship are made by senior management. Donations and sponsorship must not be used to obtain improper advantages indirectly from business partners.
Zero Tolerance for Corruption – Particular Caution When Dealing with Public Officials
Our success in the marketplace is based on performance, flexibility and commitment to service and must not be achieved through improper benefits. Our business partners rely on the professional judgement of our employees.
We therefore do not tolerate any form of bribery, corruption, acceptance of improper benefits or granting of improper advantages.
Anyone who fails to observe the rules concerning gifts and invitations set out in Section 10 risks committing a criminal offence under anti-corruption laws. Even promising or requesting improper benefits may constitute a criminal offence.
When extending invitations or providing benefits to public officials, the internal rules of the relevant public authority concerning gifts and invitations must always be observed. Providing benefits to public officials may constitute a criminal offence involving the acceptance or granting of advantages solely because the benefit is connected to their official position. It is not necessary for the benefit to be intended to improperly influence the performance of official duties. Anyone entrusted with performing public functions may qualify as a public official, not only civil servants and public-sector employees.
Prevention of Money Laundering and Terrorist Financing
Our company has implemented risk-appropriate precautionary measures to prevent money laundering and the financing of international terrorism in accordance with applicable legal provisions and supervisory requirements.
Protection of Competition
Our company does not engage in unlawful agreements or practices that restrict competition, particularly arrangements with competitors concerning prices, contractual terms or market allocation. Before employees deviate from standard contracts or procedures established in cooperation agreements, they must consult the Legal department to ensure that such deviations do not have unlawful consequences under competition law.
When interacting with competitors and business partners, employees must not discuss internal matters without prior consultation with the Compliance department. Such matters include prices, sales or financing terms, costs, market information, organisational processes or other confidential information that could provide competitors or business partners with a competitive advantage.
Protection of Company Assets and Natural Resources
The company’s assets, operational facilities, business documents and work equipment must not be misused for private purposes or made available to third parties where doing so could adversely affect the company’s interests.
Employees should endeavour to protect natural resources in their daily work and ensure that the company’s business activities have the lowest possible environmental impact through material conservation, energy-efficient planning, waste reduction and recycling. When selecting suppliers, promotional materials or other external services, every employee should consider environmental and social criteria alongside economic considerations.
Occupational Health and Safety
Processes, business premises and operating equipment must comply with all applicable statutory and internal requirements concerning occupational health and safety, fire protection and environmental protection.
Consequences of Violations
Violations of these rules may result in significant reputational damage and legal consequences for the employees concerned, their colleagues and our company, including fines, criminal proceedings or restrictions on official permits. Furthermore, violations that constitute breaches of contractual employment obligations may result in disciplinary action under employment law.
Applicability
This Code of Conduct enters into force upon signature by the management and applies without exception to all employees in Germany, Austria, Sweden, Romania and the Czech Republic.