1. Compliance with laws, regulations, accepted standards, guidelines, and principles
Sustainability stands for more than just stated assumption of responsibility in the areas of the economy, ecology, and social matters. It also stands for our company’s actions in striving to fulfill its role as an accepted part of our society through uncompromising compliance with its laws, rules, and regulations.
As a result, we are committed to compliance with the applicable national laws and regulations and uphold internationally accepted standards, guidelines, and principles, especially the principles of the UN Global Compact, the Universal Declaration of Human Rights, the conventions of the United Nations, and the core labor standards of the International Labor Organization (ILO) as well as the OECD Guidelines for Multinational Enterprises.
The principles set out in the rest of this Code of Conduct must be observed by our employees and must not be circumvented through contractual agreements or comparable measures.
2. Prevention of corruption
The relevant legal provisions on fighting corruption must be observed. In our dealings with customers, suppliers, and service providers (hereinafter “Business Partners”) as well as with government institutions, the interests of FTSAM AD and the personal interests of FTSAM AD employees must be kept strictly separate by both sides. Actions and decisions, especially purchasing decisions, must always be free of non-objective considerations and personal interests. This means that money, or personal advantages or perquisites with monetary value, must never be either accepted or offered in return for preferential treatment during business dealings.
Furthermore, our employees agree not to offer, promise, request, grant, or accept any gifts, payments, invitations, or services during the course of business dealings where so doing could affect a business relationship in an impermissible manner. Our dealings with the above-mentioned advantages and perquisites are determined by the FTSAM AD principles of legal compliance, responsibility, and appropriateness.
Appreciation and respect for every human being are high priorities for us and among our core values. Cultivating and developing each and every individual’s potential for achievement lies at the heart of management’s responsibilities toward employees. We expect our employees to identify with the Company’s goals and demonstrate loyalty with regard to the Company’s interests. With that in mind, employees should avoid situations in which their personal, family, or financial interests could conflict with those of FTSAM AD. If it becomes apparent that such a conflict of interest could arise, the person concerned should disclose it and request the approval of the appropriate manager.
We encourage our employees to report corrupt and unlawful behavior. The first point of contact is the direct supervisor or the next higher manager. If an employee does not wish to contact that manager, other appropriate communication channels are available. (See final provisions > Section ii > Dealing with reports of violations).
3. Antitrust and competition law
We expect our employees and service providers to comply with all applicable national and international antitrust laws as well as the laws against unfair competition wherever relevant to the scope of their specific responsibilities. Agreements, understandings, or activities that affect prices or conditions, allocate sales territories or customers, or impede free, open competition in an impermissible manner are prohibited.
Agreements and understandings between customers and suppliers with the intent of restricting the freedom of contractual partners concerning prices and other conditions (setting of prices and conditions) are also prohibited. Reports regarding anticompetitive behavior must be directed to the direct supervisor or the next higher manager.
For questions regarding whether certain actions are permitted under competition or antitrust law, please feel free to contact your direct supervisor or the next higher manager.
4. Confidentiality, data protection and privacy
We are committed to transparent communication within the limits of business confidentiality. Our employees agree to maintain confidentiality with regard to business and trade secrets and to comply with the laws on data protection and privacy.