Code of Conduct
Lawful, compliant, responsible and fair behaviour
As a globally active company, Trenz Electronic GmbH faces up to its social responsibility. Trenz Electronic GmbH employees always follow the principles of sustainable and responsible action, the applicable laws and the Trenz Electronic GmbH guidelines in their actions, measures,
contracts and all processes. Trenz Electronic GmbH employees are honest and reliable towards our customers, the authorities and the public. Trenz Electronic GmbH pays the applicable taxes, duties and customs, complies with competition and antitrust law, does not engage in corruption, bribery or money laundering and ensures that its products are state of the art. Necessary official approvals are obtained, export control regulations are followed and the rights of third parties are respected. Should we fail to comply with these principles, we as a company or as employees would not only be threatened with business or personal disadvantages through loss of reputation, criminal prosecution, fines or claims for damages, we would also be acting contrary to Trenz Electronic GmbH values. Therefore, it is important for us to always act in accordance with these principles, even if this means having to accept business disadvantages in individual cases. Everyone in the company is responsible for ensuring that the laws and Trenz Electronic GmbH guidelines are adhered to in our work area. The working environment must be continuously checked from this point of view and for compliance with these principles. The managers and the Compliance Department are available at any time and in confidence to discuss and clarify possible uncertainties and must also be approached in such cases. This Code of Conduct is binding for all Trenz Electronic GmbH employees, regardless of where and in which function they work. Trenz Electronic GmbH applies a zero tolerance principle in the application of this Code of Conduct, violations of which will not be tolerated and may be subject to legal or disciplinary action, up to and including termination and the assertion of claims for damages.
Indications of possible irregularities
Every Trenz Electronic GmbH employee is required to report possible or actual violations of the provisions of this Code of Conduct, Trenz Electronic GmbH guidelines or applicable laws through appropriate channels, whether through supervisors, the Compliance Department. It is better if you can give your name, but anonymous reporting is also possible. Any information will be treated in strict confidence. Any form of disadvantage or discrimination against Trenz Electronic GmbH employees who have made a report in good faith and not in an abusive manner is excluded and will not be tolerated, even in the event that the report later proves to be unfounded
Leading by example
Managers are obliged to prevent violations of legal provisions, the Code of Conduct and all other Trenz Electronic GmbH guidelines in their areas of responsibility and monitor this regularly. They shall ensure that their employees are aware of this, that the rules are observed and that violations are subject to disciplinary action, irrespective of the employees‘ hierarchical position in the company. Managers act as role models for employees and inform them about the regulations of the Code of Conduct, discuss them with them and, together with the Compliance Department, are available as points of contact. They are in regular dialogue with their employees about compliance.
Behaviour towards employees
The personal dignity of each individual is protected and respected. Discrimination on the basis of age, gender, race, skin colour, social or ethnic origin, nationality or sexual orientation, religious or political conviction or other legally protected characteristics will not be tolerated, nor will any form of physical or psychological harassment or violence. Diversity and equal treatment are a matter of course at Trenz Electronic GmbH. Employees working for Trenz Electronic GmbH must have reached the minimum age required by law. All employees have a right to freedom of association and to have their interests represented by their elected representatives. Trenz Electronic GmbH respects the statutory minimum wage and complies with the nationally applicable labour laws without exception. Inappropriate behaviour must be reported to Human Resources or the Compliance Department.
Responsibility towards society
Trenz Electronic GmbH bears considerable social responsibility as an employer and along the entire value chain. Sustainable management, fair and responsible dealings with each other within the company and with business partners, is a prerequisite for our sustainable and long-term success.
Trenz Electronic GmbH complies with all protective laws, such as the German Due Diligence Act and the equivalent laws of the countries in which Trenz Electronic GmbH operates. Trenz Electronic GmbH expressly condemns and rejects the violation of human rights and any form of forced or child labour and modern slavery, expecting the same of all business partners, and ensures that human rights are fully respected. Trenz Electronic GmbH stands for fair working conditions along the entire supply chain and the internationally recognised standards of the International Labour Organisation (ILO) are binding for Trenz Electronic GmbH. Trenz Electronic GmbH is expressly committed to the principles of the UN Global Compact and acts in line with these principles
2. Protection of relationships of trust
Avoiding conflicts of interest
Secondary employment may only be taken up after prior written approval from Trenz Electronic GmbH. Employees are only permitted to have a significant shareholding in competitors, suppliers or customers with the prior written approval of Trenz Electronic GmbH on a case-by-case basis. Business may only be done with companies in which a life partner or close family member has a shareholding or is active in a managerial function with the prior written approval of Trenz Electronic GmbH. Approval may be prohibited in each case if it cannot be ruled out that this relationship may influence the business relationship and that there is a possibility of a conflict of interest.
Dealing with information
Internal and external documents of all types, such as customer and sales documents, technical documents, financial documents, expense reports and time recording documents, must be issued correctly and truthfully and must accurately reflect the relevant transaction. The principles of legally compliant bookkeeping and accounting are complied with. Data entries and other records must be complete, correct, timely and system-compatible. Documents that are subject to a statutory retention or deletion period are treated at least in accordance with these periods. Other documents are subject to a retention or deletion period determined by Trenz Electronic GmbH.
The proper use and protection of company property is the responsibility of each employee. Company property provided may only be used for business purposes and must be handled with care and in accordance with the guidelines applicable to it.
Data protection and information security
The protection of privacy, the protection of personal data and the security of all business information are carried out in compliance with legal requirements. Data is protected against unauthorised access and loss, whereby a risk-appropriate standard is maintained that is technically and organisationally oriented to the relevant state of the art. Compliance with data protection and information security requirements is ensured at all times in all business processes. Questions in this regard will be answered by the Compliance Department as well as the Data Protection Officer.
E-mail and Internet use
Even if many e-mails have a rather informal character, every e-mail sent constitutes a business document and must be treated accordingly. E-mails must comply with the Trenz Electronic GmbH business principles. E-mails and the Internet may only be used for official purposes.
Trenz Electronic GmbH employees keep confidential information relating to Trenz Electronic GmbH as secret as information relating to its business partners. This obligation continues beyond the termination of the employment relationship.
3. Shaping Trenz Electronic GmbH business relationships
Conduct towards business partners and third parties
Competition and antitrust law
Our customers value working with us because of our competitive products, technologies and prices as well as our reliability, but not because we behave dishonestly. At the same time, we are in competition with many other companies and customers. Compliance with the rules of free and fair competition within the framework of legal regulations is an integral part of our actions and our self-image. This means that competitors are not permitted, either directly or indirectly, to divide up territories or customers, to collude or exchange information on prices, their components or other competitive parameters, supply relationships and their conditions, existing or future production capacities or supply behaviour. This also applies to exchanging information on market strategies or participation strategies. Written contracts or verbal agreements on this or tacit, coordinated parallel behaviour are generally not permitted. Agreements or information on research and development projects are only exchanged within a strictly limited and legally permissible framework and always require the involvement of the Compliance Department. Customers and buyers determine their resale prices independently and without influence from Trenz Electronic GmbH. The respective national competition and antitrust laws are fully observed. A strong market position is not abused, for example to enforce price discrimination or refusal to supply.
Supplier and customer relations
Agreements with suppliers and customers are fully and clearly documented, including subsequent changes and amendments. The internal control rules are complied with. Suppliers are selected only on a competitive basis, taking into account price, quality, performance and suitability with regard to the products and services offered.
Corruption and bribery
Trenz Electronic GmbH does not tolerate any form of corruption or active or passive bribery. Such conduct by employees or business partners is punishable by law and leads to distortions of competition as well as financial and reputational damage for Trenz Electronic GmbH. Donations to public officials or persons equivalent to them are not permitted. Even the mere appearance of influence must be avoided. Trenz Electronic GmbH employees may also not accept benefits from public officials. No benefits shall be offered or granted to public officials for performing or expediting official acts – regardless of whether there is a claim to the performance of the official act or whether the public official violates their official duties through their actions. In business dealings with customers, suppliers and other third parties, any form of corruption or bribery or other unfair influence on business decisions is not permitted, for example in connection with agreements on the procurement, award, delivery, processing and payment of orders. Services which may be assumed to be intended in whole or in part for the payment of bribes may neither be agreed upon nor provided. If representatives or other intermediaries are commissioned by Trenz Electronic GmbH to obtain orders or pprovals for Trenz Electronic GmbH, they shall be obliged in writing to act in accordance with the law and to refrain from bribing or granting advantages or accepting bribes. In the event of a violation, it must be possible to terminate the relationship with this person without notice. The giving or acceptance of gifts or other benefits is only permitted if they have negligible financial value (e.g. promotional pens or promotional mugs). Business invitations may only be extended or accepted in an appropriate setting. Any form of extravagance is not permitted.
Export and import control
Trenz Electronic GmbH complies with applicable export and import laws, such as sanctions, embargoes and other laws, regulations and government orders or policies. These laws are extensive and can be difficult to apply due to Trenz Electronic GmbH‘s global operations. The Compliance Department is available to answer questions on this matter.
Trenz Electronic GmbH is subject to certain obligations under national anti-money laundering laws that may apply or have an impact internationally. Therefore, all questionable or dubious financial transactions must be reviewed and clarified, whilst all business relationships must be continuously monitored.
Taxes, duties and customs
As a globally active group of companies, Trenz Electronic GmbH is obliged to pay various types of taxes, duties and customs. These taxes, duties and customs are calculated correctly and paid on time.
Donations and sponsorship
The management team at the respective Trenz Electronic GmbH company decides in a transparent manner, on the basis of the relevant laws and after consultation with the Compliance Department on the granting of donations in cash or in kind or sponsorship for the promotion of education, science, culture or for social and charitable purposes. Should a donation be approved, it must be appropriately documented and properly accounted for.
4. Production and development
Trenz Electronic GmbH products have stood for quality, innovation, reliability and sustainability. Trenz Electronic GmbH develops and manufactures safe and reliable products that comply with the contractual agreements made and the state of the art. In the event that conflicts arise in the practical implementation of these requirements, they will be resolved in the spirit of fair and responsible action.
Intellectual property and expertise
Intellectual property is a valuable asset. It includes industrial property rights (for example, patents or trademarks) and works protected by copyright (for example, software or image rights). Intellectual property of third parties is respected and only used if the use has been permitted beforehand. Expertise not protected by industrial property rights or copyrights may only be used if there are no legal regulations to the contrary.
Occupational health and safety and environmental protection
Safety and health protection form an essential part of our responsibility and activities. Therefore, all applicable, relevant regulations and work instructions must be followed without restriction and the legally required protective equipment must be used in each case. Economic activity and environmental protection are interdependent and form the basis of sustainable and resource-conserving value creation. In this way, Trenz Electronic GmbH makes a significant contribution along the supply chain to the sustainable use of resources (including conflict minerals) for environmental and climate protection. Trenz Electronic GmbH conserves resources by continuously adapting the production, quality and performance of its products with a view to their environmental compatibility and by reducing the consumption of energy, water and raw and operating materials, whilst using renewable energies wherever possible.
5. Reporting violations of the Code of Conduct, company policies or laws
Trenz Electronic GmbH requires all employees to report potential and actual violations in good faith. This can be done through the supervisors or their superiors. The Human Resources Department and the Compliance Department are also available for this purpose. Trenz Electronic GmbH maintains an independent compliance hotline through which possible violations can also be reported. Although it is preferable for a name to be given for easier communication and clarification of the facts, this is voluntary and there is always the option to remain anonymous. Employees who report potential or actual violations impartially and in good faith are fully protected from reprisals, discrimination or disciplinary action, even if the report is subsequently found to be unjustified. Every report is taken seriously, treated in strict confidence and processed. Trenz Electronic GmbH will not tolerate any form of discrimination against employees who report possible or existing violations in good faith.
6. Compliance Help Desk - The whistleblower system
Our compliance management system aims to create a culture of values and strengthen employee responsibility that goes beyond formal compliance with laws and regulations. This also includes jointly preventing and combating behavior that harms our company, our employees and our partners financially or in terms of reputation.
With the whistleblower system, we offer all employees and external persons a tool to ensure law-abiding behavior in the company and uncover violations.
If you identify any irregularities, please do not hesitate to report them. In addition to your supervisor, the HR department, your compliance officer or even the management are available to you for this purpose.
If you do not wish to contact these offices or wish to keep your report anonymous, you can contact the Compliance Officer or also drop the report anonymously in the "report mailbox" All information will, of course, be treated confidentially within the framework of the legal requirements.
Whistleblowers who report wrongdoing for ethical and moral reasons are not denouncers. They play a key role in preserving social values and the rule of law in our company. However, please remember that information you provide about others may lead to decisions that have consequences for these people. We therefore ask you to only provide us with information that is correct to the best of your knowledge.
In this way, with your help, criminal activity can be detected early, perpetrators can be identified, and further harm can be prevented.
You may contact any of the individuals listed.
Here you can find out how we handle tips that you have submitted using your name or anonymously via the whistleblower system and how we ensure that your identity as a whistleblower is treated confidentially.
Incoming information is received by specially designated employees of Trenz Electronic GmbH. Only to these employees can tips be made within the framework of the whistleblower system. The designated employees of Trenz Electronic GmbH receive the facts and, if necessary, forward them to an internal unit, e.g. the compliance officer of the operating unit concerned, for further investigation. If there is a corresponding suspicion, the transfer to a criminal prosecution authority may also be considered. In the course of the follow-up, it may be necessary to provide information to other employees of Trenz Electronic GmbH.
The follow-up of the information will be strictly confidential. Your name or circumstances that could reveal your identity as a whistleblower will not be disclosed to the accused person or the public, unless this is absolutely necessary in exceptional cases, e.g. due to legal regulations.
If you use the whistleblower portal in good faith, you need not fear any disadvantages. However, in the event of misuse, e.g. knowingly providing false information with the aim of discrediting a person, we reserve the right to take action against the person providing the information.
Informing the accused person
In certain cases, we are legally obligated to inform the accused persons that we have received a tip about them as soon as this information no longer jeopardizes the follow-up of the tip. Your identity as a whistleblower will not be disclosed in this process - to the extent permitted by law - and we will ensure that no other information is disclosed that would allow conclusions to be drawn about your identity as a whistleblower.
We store information for as long as it is required for follow-up or we are obliged to store it by law. Subsequently, tips will be deleted or anonymized no later than two months after the end of the investigation, i.e. the reference to your identity as a whistleblower will be permanently and irreversibly removed.