Code of Conduct
The code of conduct of the Cargodian GmbH is at the heart of our internal set of rules. It is binding for all employees, managers, and other company members of Cargodian GmbH (hereinafter referred to as “Cargodian”). We encourage and demand from all managers and employees that they always act in accordance with the applicable law and the company’s internal guidelines.
This code of conduct requires all managers and employees to behave in accordance with the law. It contains precise requirements, such as compliance with competition law and anti-corruption law, handling donations, avoiding conflicts of interest when performing their duties, and protecting the company assets.
In the following we present the company values and business principles of Cargodian and provide you with guidelines on how you can implement and live them in your everyday work.
1. Respect and Integrity
The employee is the essential resource for every company. Human dignity, respect for personal rights, and privacy are of the utmost importance to us. We respect the different cultural, ethical, and religious backgrounds and are committed to the principle of equality, regardless of age, disability, skin color, sexual identity, gender, and worldview.
We do not tolerate any discrimination based on these characteristics and sexual harassment or other personal attacks on individuals. In this context, please also note our employee information on the subject of the General Equal Treatment Act.
Righteousness and honesty in our behavior towards our business partners and employees are a matter of course for us.
2. Corporate Social Integrity
We know our role and responsibility as corporate citizen in society and act accordingly. Cargodian acts fair, legal, considerate, and courteous and contributes to promoting fair and sustainable standards, social conditions, and environmental awareness. We aim to continuously improve performance and awareness with our employees and business partners globally. We at Cargodian lead by example, and we shall always strive to act honourably, professionally, and with great professional care.
3. Laws and Regulations
Cargodian complies with applicable laws and regulations of the countries it operates in and requires that its suppliers do likewise.
4. Forced Labour and Child Labour
No forced labour of any kind, including forced labour in prisons and bonded labour may be used. No child labour is used. Unless local legislation stipulates a higher age limit, no person still of school age or younger than 16 will be employed (subject to the exceptions specified in ILO Convention 138). Employees under the age of 18 may not perform any hazardous work and may be exempted from night work considering their educational needs
5. Anti-Corruption
Cargodian’s actions are guided by generally accepted ethical values and principles, integrity, honesty, respect for human dignity, openness, and non-discrimination on the grounds of religion, ideology, gender, or ethnicity. Cargodian rejects any form of corruption or bribery as defined by the relevant UN Convention (adopted in 2005). It promotes transparency, acting with integrity, and responsible corporate management and control.
Cargodian acts according to the following principles, which are mandatory for all employees and other company members:
- No inducements may be made that are suitable to give Cargodian an unreasonable competitive advantage.
- The goals and ethical orientation of the recipients of our company’s benefits must be compatible with the values and principles of Cargodian, which are also reflected in this code of conduct.
- The identity of the recipient and the planned use of grants must be clear and made transparent.
We are categorically opposed to corruption. Cargodian shall not provide, offer, or promise, directly or otherwise, any gifts or favours to any person if the objective or consequence thereof is support for illegal or unethical conduct. This prohibition shall not only apply to our business partners (present or future), but it shall also apply in relation to public officials. “Public officials” means officers, politicians, judges, and other employees working for central or local government or for international institutions.
6. Gifts and Invitations
On the one hand, invitations and gifts are common and legitimate practice in everyday business life; on the other hand, certain conditions must be observed, and certain limits must not be exceeded. For this purpose, the following provisions shall apply to Cargodian, based on which our employees and managers must conduct their behavior:
- The gift must be granted or accepted in a transparent manner, i.e., it must be externally recognizable and verifiable.
- It may not be offered or accepted as consideration for consideration.
- Gifts in the form of money and their equivalents are strictly forbidden.
- The frequency of previous contributions to the same recipient must not create the appearance of dishonesty.
- The gift or contribution may not exceed a value of 35 euros.
Benefits requiring approval, e.g., invitations to entertainment events and other benefits (particularly gifts and dinner invitations), must be approved in advance by the Compliance Officer (email to: compliance@trustnet.trade). If additional benefits are intended to be given to public officials or persons closely related to them, their compatibility with the applicable guidelines must be checked in advance.
7. Communication
In all their activities, our employees and associates must proceed in accordance with legislation, Cargodian internal regulations, and, first and foremost, this Code of Conduct. We are not tolerating unlawful conduct even where it might be described as an “everyday business practice.” We will not help anyone to engage in illegal conduct. We at Cargodian reject all unlawful or unethical conduct of our employees, associates, suppliers, customers, and other persons. We shall strive to detect and combat all unlawful activity that might take place in connection with our business operations. We are aware of the consequences of breaking the law, and we shall inform our employees of such consequences. Those consequences may be:
- the imposition of steep fines on Individuals or Companies;
- the obligation to pay significant damages to all harmed parties;
- the imprisonment of Individuals;
- the irreparable tarnishing Cargodian and individuals reputation;
- the revocation of business permits or the complete shutdown of our business.
8. Competition and Antitrust Law
Cargodian is interested in free and fair competition. Every employee is required to comply with the competition and antitrust law provisions. We are guided by the following basic principles:
- No agreements or coordinated behavior with competitors about prices, price increases, conditions, or capacities, including profit, profit margins, costs, sales and marketing methods, or other factors relevant to competition, such as agreements about non-competition, division of markets, etc.
- No inadmissible exchange of competition-sensitive information with competitors.
- No industrial espionage, bribery, theft, and dissemination of knowingly false information about our competitors, their products, or service.
9. Dealing with In-House Resources
The company’s resources are to be used sparingly and treated with care. In their actions, the employees must always orientate themselves towards the principle of economic efficiency.
Employees are also required not to use company resources and operating resources in an inadmissible personal, illegal or unauthorized manner. All employees take security measures to protect the IT systems accordingly.
10. Confidentiality
Company and trade secrets as well as confidential information of any kind are to be kept strictly confidential and may not be disclosed to third parties during or after the period of employment with Cargodian or made accessible in any way.
The direct or indirect use of confidential business information during or after the termination of the employment relationship for the personal benefit of the employee or a third party or to the detriment of Cargodian is strictly prohibited.
All employees and company members of Cargodian are obliged to actively protect confidential data against access by third parties (defense against company espionage).
The right to informational self-determination of employees, other company members, and business partners must always be observed. Responsible and conscientious handling of personal data is part of the respect for the privacy of other employees and our business partners.
11. External Communication
Official statements, especially to the media, are exclusively made via the persons expressly authorized for this purpose. In order to ensure a uniform appearance and the integrity of communication, our employees are obliged to forward inquiries from the media, analysts, or any other person or institution immediately via their manager to the management of Cargodian.
12. Compensation and Benefits
Compensation, including wages, overtime, and benefits, must be equal to or exceed the levels stipulated by applicable laws and regulations. Compensation for full-time employment must be sufficient to meet the employee’s fundamental needs.
13. Working Hours
Unless national regulations stipulate a lower maximum number of working hours, and except in exceptional business circumstances, employees will not be required on a regular basis to work a standard working week more than 48 hours per week or total weekly working hours more than 60 hours (including overtime). Employees are to be given the equivalent of at least one day off in every 7-day period.
14. Health and Safety at Work
To prevent accidents and injuries, employers will provide a safe and healthy working environment and, if necessary, safe and healthy residential facilities, which at a minimum comply with applicable statutory requirements.
15. Environment
The company implements and continuously improves environmentally friendly practices in all facilities in which it operates. It meets the environmental protection requirements and standards applicable to its respective facilities and uses natural resources responsibly.
16. Whistleblowing and Protection of Whistle-Blowers
To combat illegal or unethical conduct, Cargodian encourages current and former employees’ third parties to provide timely and active notification of unlawful and unethical conduct, orders to engage in such conduct, and any suspicions thereof. We support open and fast communication at all levels so that any problems can be identified and appropriately addressed in a timely manner. Cargodian provides the following contact channels for the notification of unlawful conduct (or any suspicions thereof) and the collection of inquiries and improvement proposals related to Compliance or this Code of Conduct:
Email address: compliance@trustnet.trade
Suppose the Compliance Officer or members of the governing, management, or supervisory bodies are suspected of unlawful conduct. In that case, a notification may be sent directly to any of the members of the supervisory board of the company affected by the infringement.
We shall ensure the confidentiality of the notifier and the information received. Any notification shall be properly investigated, and an anonymized report shall be drawn up thereon that does not contain details that could identify the notifier. Employees or associates who make a notification in good faith shall not suffer any punishment or discrimination for such notification.
17. Money Laundering
Money laundering denotes conduct intended to conceal the illegal origin of money in a bid to give the impression that it has been obtained legally. More broadly, it also includes the financing of illegal activities with legal resources. Cargodian shall strive to comply with rules combating money laundering in the broadest sense. Under no circumstances shall we participate in activities associated with money laundering. We shall always stand ready to comply with all obligations deriving from national and international money laundering legislation.
18. Sanctions and Embargos
As a global business we shall respect the rules of cross-border business and taxation, including international sanctions. We shall thoroughly analyze every single trade transaction, whenever possible, by automated processes in line with defined rule criteria.
19. Engagement with Public Officials and Nation States
We shall engage with all public officials courteously. Only employees authorized by their position shall negotiate with public authorities. We shall disclose only truthful information about our company in accordance with legislation. We shall cooperate with all oversight and inspection bodies and other public authorities. We shall keep due and truthful accounts on all transactions. We shall pay tax and make social security and health insurance contributions dutifully and on time, and we shall make all other obligatory payments. As a global business, we shall also respect the rules of cross-border business and taxation, including international sanctions. We shall thoroughly analyze every single trade transaction.
Rohrdorf, December 2021