The Code of Conduct

 

 

1. OVERVIEW

1.1. The Code of Conduct of INERATEC GmbH (the Company) is one of the ways to bring Company’s values into practice. The cornerstone principle is a recognition that everything that we do in our work at the Company shall comply with the highest possible standards of ethical business conduct.

1.2. The Company takes seriously its environmental and social responsibilities. Being a member of the United Nations Global Compact, the Company commits to the Ten Principles and the International Bill of Human Rights.

1.3. The Code of Conduct defines the principles for our employees. The Company’s management fully supports the principles as set out in this Code of Conduct and expects its employees to comply with it. We also expect compliance with these principles from our suppliers.

1.4. The Company requires that all employees conduct themselves according to the highest standards of ethics, integrity, and behaviour when dealing with our clients, colleagues and other stakeholders. This includes, but is not necessarily limited to, full compliance with all legal obligations imposed by the articles of association or by the applicable law. In case of questions or uncertainties regarding these obligations, HR department can be contacted.

1.5. This Code establishes the standards of behaviour that must be met by all employees. Where these standards are not met, appropriate disciplinary action as provided by labour law will be taken. In cases where the breach involves serious misconduct, this may result in summary dismissal. In cases where a breach of the policy involves a breach of any law, the relevant authorities may be notified.

1.6. This Code of Conduct applies to all suppliers of the Company and defines minimum standards for our suppliers, their employees, and subcontractors. The Company expects compliance by its suppliers with the applicable laws and regulations of the countries where they produce, offer, or supply products or services.

2. OPERATION

2.1. The purpose of this policy is to make clear what the Company expects from employees and suppliers. Employees and suppliers are required to be familiar with this policy and comply with its terms at all times. Failure to do so by employees or suppliers may result in disciplinary action, including potential termination of employment and contracts with suppliers.

2.2. As far as this policy imposes any obligations on the Company, those obligations are not contractual and do not give rise to any contractual rights. To the extent that this policy describes benefits and entitlements for employees, they are discretionary in nature and are also not intended to be contractual. The regulations set out in this Code are issued to our employees as part of the employer's right to issue instructions.

2.3. The Company will provide employees with regular Code trainings and assess their compliance with it.

2.4. The Company may unilaterally introduce, vary, remove or replace this policy at any time.

2.5. HR department is responsible for regularly review and update the Code of Conduct.

3. STANDARDS OF CONDUCT

3.1. LAWFUL CONDUCT

Compliance with all laws.

Lawful and responsible conduct is one of our fundamental principles. 

The Company complies with all applicable laws and regulations of Germany and each country where it conducts business. The Company bases its activity on the international regulations applicable to the Company. 

The Company complies with all regulatory obligations towards the competent authorities.
Compliance with all workplace policies, procedures, rules, regulations and contracts.
Employees must comply with all workplace policies, procedures, rules, regulations, and contracts. They shall be familiar with all relevant workplace policies, procedures, rules, regulations, and contracts, observe them, and strive for compliance in line with the Company's values. 

The Company supports employees in preventing any violations. in particular by providing appropriate information and instructions and establishes a regulatory framework to ensure the lawful conduct of the Company at all levels. 

The Company establishes appropriate processes and internal guidelines to fulfill its responsibilities in different areas, including the regulatory, covered by this Code of Conduct. The Company ensures appropriate and truthful documentation of all relevant business operations.  
Compliance with export control, economic sanctions, and anti-money laundering rules

At the Company, we ensure compliance with all the relevant regulations regarding export control, economic sanctions, and anti-money laundering rules. In order to deliver technology or e-fuels, and provide services, foreign trade authorization requirements must be followed. We take every possible measure to verify the identity of our customers to prevent money laundering and terrorist financing. It is strictly prohibited to conduct any transactions with individuals, companies, or organizations that are listed on the sanctions list.

Compliance with lobbying regulations

The Company is neutral regarding political parties. However, where appropriate, the Company participates in a legitimate manner in political discussions and processes that are relevant to the Company, its products and its customers. The Company complies with all obligations arising from applicable statutory requirements, e.g., the Lobbying Register Act (Lobbyregistergesetz, LobbyRG) in Germany, its federal states and in each country where the Company conducts business.
 

3.2. ENVIRONMENTAL AND CLIMATE PROTECTION

Development of environmentally friendly technologies and climate-neutral e-fuel production.

The Company supports initiatives for the promotion of greater environmental responsibility and encourages the development and distribution of environmentally friendly technologies. The Company endeavors to assess and implement projects considering environmental impact as a fundamental criterion for the evaluation of the projects. We are committed to developing technologies to produce climate-neutral e-fuels for decarbonization of the hard-to-abate sectors.

Support of the environmental and climate protection actions

The Company recognizes the importance of preserving the environment by continuously striving to minimize the negative environmental effects of our actions and by actively contributing to environmental and climate protection.

The Company develops power-to-x technologies, produces e-fuels using electricity or hydrogen from renewable energy and recycled CO2 as feedstocks, in a way that avoids negative environmental impacts and minimizes the consumption of natural resources, raw materials, waste and wastewater. The Company is committed to mitigating its impact on life on earth by working to preserve ecosystems.

The Company is a fair and innovative player in the low-carbon transition, which works to truly share value with its stakeholders. It mobilizes a significant part of its Research and Development (R&D) and innovation efforts for this purpose.

The Company supports efforts for climate protection and does not cause serious environmental damage. Our sustainable business practice is based on compliance with all rules and standards, supporting in particular all efforts to avoid air and water pollution and soil damage. To prevent or minimize environmental risks, the Company complies with local environmental laws and regulations and with international conventions.

Responsibility for the environment also includes the prudent and efficient use of resources. The company optimizes the use of its resources and waste, as well as the promotion of sustainable practices in its value chain.

The Company contributes to universal access to clean energy, the development of renewable energy and improved energy efficiency. Through green financing, it is working to accelerate the transition to a low-carbon economy.

The Company respects and actively contributes to the protection of biological diversity in our business activity.

Responsible minerals sourcing plays an essential role for the Company. It should be traceable in the supply chain of our technologies and in compliance with EU legislation.

The Company respects rights to land, forests, and water and does not accept any unlawful actions in this regard.

3.3. FAIR LABOR PRACTICE

Respect for Human Rights

The Company respects internationally recognized human rights, labor, and social standards and supports their protection.

The Company and our suppliers must not make use of child labor or tolerate any form of slavery, forced labor, or comparable forms of exploitation. Our employees carry out the work without violating their personal rights and based on their free will.

Fair Labor and Employment Practices

The Company acts based on fair labor and employment practices to ensure our employees are treated in accordance with the applicable laws and regulations.
The Company pays the employees appropriate and fair wages in a timely manner in compliance with the applicable law. At the same time, the employees devote all their time, attention, and skill during contractually owed working hours.
 

3.4. HEALTH AND SAFETY RULES

Compliance with health and safety rules

Compliance with health and safety rules are top priorities at the Company. Health and safety rules must be strictly observed by employees at the workplace to prevent health hazards.

The Company operates its facilities in strict compliance with safety regulations to reduce the risk of accidents and ensure that its production processes operate smoothly.
 

Ensuring compliance with the Life Saving Rules

Life-Saving Rules have shown their effectiveness in preventing fatal accidents. These rules have been developed to ensure the safety of our employees and the people who work with us.

It is highly important to follow the rules below to prevent accidents:

• Obtain a valid permit to work when required.
• Use protective equipment to prevent falls when working at height.
• Take necessary precautions when working in confined spaces.
• Adhere to electrical safety guidelines.
• Carefully manage lifting operations and danger zones.
• Wear personal protective equipment.
• Follow safe driving practices.
• Stay clear of the line of fire to protect yourself and others.
• Do not deactivate or bypass safety critical equipment such as interlocks and guards when using machinery.

Quality of our technologies

Quality is a crucial aspect of ensuring safety, and we are continuously working towards enhancing the quality and efficiency of our power-to-x technologies. Following strict processes and procedures, we ensure compliance with our customer's requirements for the products and services we provide. Team collaboration allows us to continuously enhance our processes and procedures.
 

3.5. COMPANY’s PRODUCTS, CLIENTS AND MARKETS
 

Compliance with competition laws

The Company is committed to fair competition through compliance with all antitrust, competition, and fair trade laws. There is no place for tolerance of anticompetitive conduct. We expect the same approach from our competitors and business partners.

Fair treatment of contracting partners

The Company cooperates with contracting partners in different areas. The key precondition for our successful collaboration is honesty and fairness in dealings with customers, clients, co-workers, Company management, and the general public, as well as courtesy and respect.

3.6. AVOIDANCE OF CONFLICT OF INTERESTS

Compliant behavior without personal conflicts of interests

All our employees must act in the best interests of the Company and avoid any conflicts of interest in situations where their loyalties can depend on the Company's interests and their personal interests.

Employees must avoid every possible conflict of interest, with particular regard to personal or family considerations (e.g., the existence of a vested interest with a supplier, customer or competitor etc.) which might affect the independence of judgment when deciding what is in the Company’s best interest and what is the most appropriate way to pursue it.

To prevent any conflicts of interest, all our employees must immediately disclose any potential, perceived, or actual conflict of interest that may give rise to a conflict with the performance of the employee’s obligations to the Company. Employees must not be engaged in any employment or provide services to any person or company without prior written consent of the Company.

3.7. ANTI-CORRUPTION

Prohibition of any corrupt practice

The Company prohibits any corrupt practice, including bribery and other unlawful payments in the public and the private sectors.  All our employees may not accept any financial or other benefit in connection with employment at the Company from any entity or person other than the Company – unless the acceptance of such benefit is in accordance with the Company’s other workplace policies or is otherwise disclosed to the Company and expressly permitted by the Company.

All our employees may not accept any financial or other benefit that could, in any way, influence, or appears to influence their business decisions. The Company observes applicable laws and regulations with respects to giving and receiving any benefits.

3.8. COMMUNICATIONS

Responsible media relations and public statements

Our business activity is monitored by the media. When dealing with anyone outside the Company, employees must take care that the Company is portrayed according to its vision and in line with its values.  All our employees may not make any statements to the media about the Company’s business, unless expressly authorised to do so by the Company.

Using social media, employees must not make any statements about the Company on social media, or any other public platform, that may harm the Company’s reputation.

All our employees must not engage in conduct, whether during or after work hours, that in the opinion of the Company causes damage or potential damage to the Company’s property or reputation.

3.9. MUTUAL APPRECIATION AND PRINCIPLE OF NON-DISCRIMINATION

Equal treatment of all employees and all people

The Company strives to promote diversity and ensures equal treatment of all employees and people.
Our employees' diversity drives our innovations. The Company is committed to hiring, promoting, and training employees without any discrimination.

Further, the Company contributes to economic development by participating in a just transition and providing access to decent jobs without discrimination. This inclusive contribution allows it to develop talented individuals while making equal opportunities a reality.

Compliance with the principle of non-discrimination

The Company ensures a respectful working environment where every employee is respected as an individual. We work at our workplace in a way characterized by appreciation, mutual understanding, openness, and fairness. We are not tolerant of discrimination and harassment.

Disadvantages based on ethnic origin, skin color, nationality, gender, religion, age, sexual orientation, or other characteristics have no place in the Company. The Company commits to addressing harassment, bullying, reprimand, violence, aggression and other forms of inappropriate behaviour through disciplinary measures as provided by labour law.

All our employees must always behave in a way that upholds the Company’s core values and the company's integrity and good reputation.

3.10. DATA PROTECTION

Compliance with data protection requirements

The Company fulfills all legal data protection requirements, including its data protection guidelines and all contractual obligations. Strictly compliance with the requirements for the personal data protection of our customers, employees, and business partners is also among our priorities. Recording, processing, and the use of personal details are performed only in compliance with the applicable laws and regulations.
 

Responsible handling of confidential information

Confidential information means any information that has not been publicly disclosed. The Company safeguards its confidential information and the confidential information of our customers and business partners.
Confidential information that becomes known to our employees may only be used according to authorizations.

These principles and obligations apply during working and non-working hours and whether the information is specifically designated as confidential or restricted. Employee’s confidentiality obligations do not expire if their employment with the Company ends.

Any facts of possible mishandling of confidential information must be reported by our employees to the Company.

Protection of innovations and intellectual property

Innovations in power-to-x technologies and intellectual property (IP) are among Company's most valuable assets, distinguishing us from other competitors. Our innovations and intellectual property must be appropriately protected. To maintain our competitive edge, our innovations are protected by the available legal options by securing intellectual property rights in patents and design rights.
The Company also respects the legitimate IP rights of others. If employees duplicate or misappropriate someone else's IP without authorization, employees and the Company may be subject to significant fines and criminal penalties.

IT-Security

IT systems – hardware, software, networks and the information that runs on them – are critical to the Company’s business success and must be protected. Everyone who uses a computer is responsible to use these resources appropriately, securely and for intended business uses. Employees are requested to pay particular attention to the IT aspects of confidentiality, such as data protection and data security. Employees must take actions to protect their computer, or other electronic devices from unauthorized use or access.

4. IMPLEMENTATION OF THE CODE OF CONDUCT

4.1.  Employees are required and encouraged to report any conduct of other workplace participants which is in breach of any of the Standards of Conduct, or potentially in breach of any of the Standards of Conduct, without delay. Therefore, we have implemented a Whistleblowing system. 

4.2. Employees can discuss any questions about the application or interpretation of this Code, its general underlying principles or specific legal requirements or about Compliance in general, with their manager.

4.3. Employees and third parties with specific questions, concerns and observations can contact the persons designated for this purpose in the Organisational Structure List in the Annex of this Code of Conduct. Both officers and authorised representatives are referred to as ‘Officers’.

Everyone can also get in touch with the Company:
Telephone: +49 721 8648 4460
Email: info@ineratec.de