Code of Conduct

Applicability

This Code of Conduct describes the ethical principles and general guidelines that the economic activities of USP Indicator Solutions GmbH are based on and that represent significant elements of its corporate culture. It applies to the management and employees of USP Indicator Solutions GmbH.

The aim of this Code of Conduct is not to present each possible constellation conclusively.  Instead, it is intended to provide guidelines for each employee and manager towards which their self-responsible everyday behavior should be oriented.

Each manager and each employee contributes through their behavior to the best possible implementation of these guidelines, thereby making a contribution towards “clean” business.  The management must fulfill an exemplary role and bears a special responsibility for the communication and practice of these guidelines.

To improve readability, gender-neutral formulations are used in this Code of Conduct.  However, it is explicitly targeted towards both female and male employees and managers.  USP is committed to comprehensive gender equality.

 

1 | Behavior compliant with laws and regulations

In all areas of corporate activity, USP is subject to laws, directives and other regulations.  This refers to legal directives on a European and national level, as well as corporate regulations (e.g.: corporate guidelines, internal instructions) and regulations based on voluntary commitment (e.g.: Corporate Governance Codex).

The integrity of all actions is a significant precondition for long-term successful business.  For this reason, the actions of USP and its employees must only be within this prescribed and frequently modified framework.  USP itself will do all that is necessary to inform its employees about the regulations relevant to them and provide guidelines for compliance.

 

2 | Corruption and its prevention

| a. General information

Corruption refers to morally objectionable behavior aimed at personal advantages at the expense of (natural/legal) persons or the public.  It is characterized by the abuse of a public or comparable economic function through which laws or other behavioral norms are infringed.  Corruption damages our reputation as employees and the reputation of USP, as well as of the economy in general.  USP, therefore, does not tolerate any behavior where business is conducted in an unethical manner.

The effective prevention of corruption requires the support of each individual employee.  All employees are required to signal a clear “no” to corrupt practices through their actions.  This includes not only setting a positive example within their surroundings through their own active behavior but also reacting appropriately to the dubious practices of others.  USP is constantly striving for the improvement and further development of its measures for combatting corruption.  You are therefore invited to submit your wishes, complaints and improvement suggestions at any time.

USP attaches importance to a working climate that is characterized by mutual trust.  Trust requires the responsible and ethically correct behavior of each individual employee.  Always bear in mind that you yourself are responsible for your actions.  After critical self-evaluation, if you reach the conclusion that a certain behavior in a situation was not explicitly forbidden by this Code, but was nevertheless inappropriate, misguided or otherwise ethically dubious, act according to your best conscience and the ensuing stricter standards.  Consider that the benefits that the individual gains through corrupt behavior are mostly only of short duration and are disproportionate to the permanent loss of trust in daily interactions, as well as all its consequences.  Through corruption, you primarily harm yourself.

| b. Legal framework

Legal directives are the cornerstones of our actions and must be complied with.  However, by no means do the stated regulations form the only basis of our behavior.  Not everything that is legally (just about) permitted is also morally unobjectionable or tolerated by USP. 

| c. Granting of privileges

Benefits can be offered, promised, granted, claimed or accepted in various situational constellations.

If an employee is supposed to be prompted by a privilege to carry out or not carry out an action that constitutes a breach of duty, this represents bribery or corruption.  Both are prohibited in all cases.

If an employee is supposed to be prompted by a privilege to carry out or not carry out an action that constitutes a breach of duty, this represents a granting or acceptance of privileges.  The granting of a privilege is also prohibited in all cases.

If there is a granting and/or acceptance of privileges with the intention of influencing a customer, this constitutes the granting or acceptance of a privilege for the purpose of influencing.  The granting of a privilege is also prohibited in all cases.

However, it is also possible that there is a granting or acceptance of privileges that are not aimed at all at influencing persons.

In daily business interactions, there are often exchanges of gifts or courtesies that merely express appreciation towards the business partner and represent no value or only a minimal value.  Representation tasks are often associated with the extending and acceptance of invitations.

The following applies in principle: As part of your work for USP, you may neither accept privileges from other persons nor extend privileges to other persons.  However, it should not be made impossible for you to participate in business interactions.  Within the acknowledged practices of business interactions, you are of course allowed to foster social contacts.

When may you grant benefits to other persons as part of your work for USP?

You may not grant any requested privileges.

You may only offer, promise or grant benefits if these are within a customary and appropriate social context.

The following applies to benefits that are not invitations: In principle, you may only offer, promise and grant benefits to other persons if these are not improper advantages.  It can be assumed that it is not an improper benefit if all of the following conditions are fulfilled and if you can answer all of the following questions with “yes”:

  • The benefit is an everyday token of appreciation of little value.
  • The benefit does not consist of a money payment, regardless of the amount.
  • You are giving the benefit voluntarily out of politeness and not because it was demanded by the gift recipient (even if just implicitly) or because you want to achieve a certain behavior with it.
  • Upon critical and objective observation, it does not create the impression that you wish to prompt a certain behavior from the recipient by offering the benefit.
  • The granting of benefits to persons does not occur regularly at short intervals, even if they are merely low-value benefits.
  • If you are not able to answer even one of these listed points with “yes” beyond any doubt, you may not even offer the intended benefit, let alone actually grant it.

Customary guest gifts to business partners that correspond to the traditions of hospitality and politeness may be granted by management organs and sales employees.

You may extend invitations to business dinners, company events (Christmas parties, presentations etc.) or other events if these are within a customary and appropriate social context and there is an objective and justifiable interest in the invitation. 

What else must you take note of when dealing with the granting of benefits?

Ensure the greatest possible transparency: In case of doubt, confer with your line manager before you offer or accept a benefit as part of your work for USP.

 

3 | Secondary employment and company shareholding

The employee is obliged to dedicate their full working time to the service of the employer.  Secondary employment of any kind, therefore, requires prior written approval by the employer.

 

4 | Handling assets

USP employees must handle the property of USP properly and with care, as well as ensure its efficient use.  In addition, they are obliged to protect the property of USP against loss, damage, misuse, theft, misappropriation or destruction.  Each situation and each incident that could lead to such a result must be notified to the management immediately.

 

5 | Data protection

| a. Duty of confidentiality

The employer is obliged to maintain strict confidentiality towards its customers and non-compliance can lead to contract penalties.

The employee is obliged to maintain confidentiality about the operational and business matters of the employer for the duration of the working relationship and also beyond it.  The information and facts relevant to business received as part of the working relationship and through the open information policy of the company represent business secrets.  The passing on of confidential messages or information can constitute grounds for dismissal and lead to damage compensation claims.

| a. Data protection

The employee is obliged to uphold data secrecy in accordance with the specifications of the valid version of the General Data Protection Regulation.  Beyond this, the employee is obliged to ensure data protection and data security, regardless of whether it is due to a legal obligation or corporate regulations.  This duty to uphold data secrecy also continues after the end of the working relationship.

The protection of data is set out in the “Data Protection Declaration for Employees”.

 

6 | Competition

If USP has competitors on the market, it is committed to the principles of fair competition and business behavior and asserts itself through quality and the continual improvement of its services.  Improper business practices such as statements that damage creditworthiness, the disclosure of business secrets or agreements with other competitors are impermissible and are rejected by USP.

 

7 | Partnership with suppliers

USP does not view its suppliers merely as occasional business partners but strives for a fair and trusting partnership with them, in which services, return services, opportunities, and risks are in a balanced relationship.

USP expects its partners to comply with the principles of ethical and sustainable business.  USP strictly rejects a cooperation with companies who infringe existing laws or who do not feel obliged to comply with the principles set out in this Code of Conduct.

If you are involved with concluding contracts, consider this objective in your work.  If you become aware that a partner is infringing existing laws or otherwise contravening the principles of ethical business, or if you identify a significant risk of such a contravention, notify your line manager immediately. 

 

8 | Environmental protection

USP is aware of its exemplary function and responsibility within society in general and feels obliged to adhere to the principles of sustainable and resource-efficient business.

Measures to improve environmental protection are very important to USP in everyday working life.

As a USP employee, you are therefore required to make your contribution to environmental protection and sustainable business. 

 

9 | Responsibility / consequences

Contraventions of this Code of Conduct can represent a failure to honor professional duties, are associated with a representation risk for USP and its employees and can therefore also lead to legal and economic disadvantages.  For this reason, contraventions are not tolerated in principle and are sanctioned appropriately in accordance with the legal possibilities.