Compliance Guideline of the IWN GmbH & Co. KG

Dear Business Partners,
Dear Employees of our customers and our suppliers,
Dear Employees of the IWN.

For more than 45 years, IWN has earned a good and fair reputation as an employer, as a customer, and as a supplier. This is to remain so, and is to be extended further.

We want to define the essential cornerstones of cooperation in this compliance guideline so that the fundamental rules of our conduct within IWN, as well as towards our business partners and the public are made transparent.

As owner of IWN, I expect all employee, and in particular the managers, to strictly adhere this compliance guideline.

I ask all business partners, customers and suppliers to respect our code of conduct.

Many thanks
Reinhold Schulte
Director and Proprietor


The term `Compliance`
Compliance means that existing laws are kept to, just the same as other regulations and also internal instructions. On the one hand, this is a duty, on the other hand, however, also a help because the keeping of these regulations also provides security and safety.

Area of application
This guideline is valid for all employees of IWN GmbH & Co. KG.

Fundamental duties of every individual
All employees are obliged to inform themselves about the laws, regulations and internal instructions that apply for their area of responsibility, and to complies with them. A special responsibility lies with the supervisors and managers.

The reputation of IWN GmbH & Co. KG is to be respected and to be supported. The relations with each other and with business partners have to be fair, respectful and trustworthy.

Conflicts of interest between work and private matters are to be avoided.

Nobody must be provided with undue advantages. The management is to be informed of violations of this guideline immediately.

Discrimination
Discrimination on the grounds of origin, gender, religion, ideology, disability, age or sexual identity is prohibited. This applies in particular to dealings with colleagues and business partners and when hiring, promoting or dismissing employees.


Bribery and corruption
It is prohibited to offer, promise or grant a personal advantage to anyone for the performance or omission of an act.

This applies both in Germany and abroad and also prohibits bribery by third parties

Competition law and antitrust law must be observed.


Conflict of interest
The private interests of every employee and the interests of IWN are to be separated strictly.

Conflicts of interest may arise in particular in connection with orders placed with related parties, orders placed with companies in which related parties work or are involved, or in connection with activities for companies that are competitors or rivals.

In these cases, the management is to be informed. This form of honest dealings with each other ensures that a conflict of interest cannot arise.


Money laundry
IWN GmbH & Co. KG works only and exclusively with reputable business partners. Any knowledge or suspicion of, the use of illegal funds or black money must be reported immediately to the management.

Cooperation with customers and suppliers
This guideline is an instruction to all employees of the company IWN GmbH & Co. KG. Nevertheless, a compliance guideline is not possible without the involvement of customers and suppliers. IWN expects all customers and suppliers to comply with all applicable laws: to refrain from corruption, to respect human rights, to comply with the laws against child labor, to comply with the laws of international trade, in particular to comply with export and import bans as well as embargo regulations, to protect the health and safety of all employees, to comply with the relevant national laws and international standards on occupational safety, environmental protection and data protection, and that these points are also implemented and complied with in its own supply chain.
In this context, IWN has a simple arrangement for handling the following:

Invitations, presents as well as other personal advantages
IWN employees may not demand, be promised or accept personal advantages for themselves or for persons close to them. There are exceptions:

  • for invitations to business meals that are within the usual and appropriate scope
  • for invitations to general events (customer events, inaugurations etc.)
  • for small courtesy gifts (“freebies”, i.e., calendars, ball-point pens, flowers etc.)


Customers and also suppliers are requested not to bring IWN employees into conflicts of interest, by offering or providing any personal advantages or gifts.

Final instructions
This compliance guideline is to be considered as a work instruction for IWN employees. Violations will be punished under labor law, and criminal consequences are possible.
Violations of this policy are to be reported immediately to management, both confidentially and anonymously.

If you have any questions, are in any doubt, or in the event of a violation, please contact our Compliance Officer in confidence.


Contact data, Compliance Officer:
IWN GmbH & Co. KG
CFO
Bernd Brinkmann
Oldernholz 3
33719 Bielefeld
Germany
  
Fon +49 (0) 521 972 19-868
E-mail compliance(at)iwn.de