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 40 years, IWN has maintained a good and fair reputation as employer, as customer, and as a supplier. This shall remain so, and shall be extended further.

We want to stipulate in this compliance guideline the key points of our relationship so that the basic rules of our behaviour within the IWN, as well as with regard to our business partners and to the public in general, are made transparent.

As proprietor of IWN, I expect from every employee, and in particular from every person with management or supervisory responsibility, to follow this guideline strictly.

I ask all business partners, customers and suppliers, to respect this, 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 rules 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 provides also security and safety.

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

Fundamental duties of every individual
Every employee must inform himself/herself about the laws, rules and internal instructions that are valid for the their own area of responsibility, and to follow them. A special responsibility lies here with the supervisors and managers.

The reputation of the company 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 unjust advantages. The management is to be informed of violations of this guideline immediately.

Discrimination
Placing anybody at a disadvantage, because of his/her race, origin, gender, religion, beliefs, handicap, age, or sexual identity, is strictly prohibited. This is valid in particular when dealing with colleagues, but also regarding contact with business partners. It is valid when recruiting, advancing, or dismissing employees.

Bribery and corruption
It is prohibited for anybody, no matter who, to offer a personal advantage or to promise an advantage, for the purpose of getting that person to do, or not to do, something which is not ethical or correctly within his/her jurisdiction.

This is valid at home and abroad and prohibits also any form of bribery through a third party.

Attention is to be paid to laws governing competition rights and restrictive trade practices.

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

Interest conflicts can arise in particular in the case of (purchase) orders involving persons who are close, or involving companies in which close persons work, or involving activities for enterprises which are competitors and/or rivals.

In such cases the management is to be informed. In this way, transparency is secured and honest dealing is ensured because a conflict can not arise.

Money laundry
The IWN GmbH & Co. KG works together only with serious business partners. Every knowledge of, and even every suspicion of, the use of illegal financial trading (so-called “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 without inclusion of customers and suppliers is not possible. IWN expects the compliance of all valid laws from its customers and suppliers: the refraining from corruption, the observation of human rights, the compliance with the laws against child employment, the observation of the established rules for international trade and economic traffic, in particular the compliance with export and import prohibitions, as well as embargo regulations, the protection of the health and safety of all employees, the compliance with the relevant national laws and international standards for industrial safety, for environmental protection and for data protection, as well as that these points are promoted and observed in the respective supply chains. In this connection, IWN has a simple arrangement for dealing with:

Invitations, presents as well as other personal advantages
Employees of the company IWN may not expect personal advantages, neither for themselves nor for persons close to them, to be made or promised nor may they accept such. The only exceptions are:

  • for invitations to business meals, held in the usual and suitable form
  • for invitations to generally usual events (customer events, openings etc.)
  • for small trade-gifts (“freebees” ie calendars, ball-point pens, flowers etc.)


Customers and also suppliers are asked not to bring IWN employees into a situation of possible conflict of interest, by offering any personal advantages and/or presents or by arranging personal advantages and/or presents.

Final instructions
This compliance guideline is to be considered as an official Company Instruction for the attention of all employees of the company IWN. Violations shall be treated seriously and legal consequences are possible.

The management is to be informed of violations of this guideline immediately. This can be done confidentially, and even anonymously.

In case of any questions, in cases of doubt and for reporting violations, you may trustingly contact our Compliance Officer.

Contact data, Compliance Officer:
IWN GmbH & Co. KG
Commercial Manager
Andreas Hübert
Oldernholz 3
33719 Bielefeld
Germany
  
Fon +49 (0) 521 972 19-281
E-mail andreas.huebert@iwn.de