Transparent and responsible management
This Code of Conduct is a binding guideline for all employees of the company and all subsidiaries. Where national laws impose stricter regulations on foreign subsidiaries, these take precedence.
The Code of Conduct is based on our ethical values and the business principles based on them, which are characterized by integrity and loyalty. As honest entrepreneurs, we are committed to the highest ethical standards. We have a great responsibility to our customers. Our customers as well as our business partners can trust us. This includes in particular that we always comply with the law, compete fairly and are reliable partners. We are convinced that this is the only way to secure competitiveness and thus employment and economic success in the long term.
The Code of Conduct cannot and does not aim to regulate everything. It contains principles and minimum standards that are equally binding for all employees and must be lived by them. In addition, we want to encourage all those who work with us to adopt these principles as well.
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The Code of Conduct serves to implement our principles of behavior:
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Integrity and lawful conduct determine our actions
Our actions are characterized by securing and expanding our top position as one of the world's leading photo laboratories and technology leaders in industrial photofinishing.
Our business relations are fact-based and free of unfair methods
We avoid conflicts between WhiteWall's interests and private interests
We treat business information or trade secrets confidentially
We do not tolerate any abuse of our own position for personal benefit, for the benefit of third parties or to the detriment of WhiteWall
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1. Principles in dealing with employees, customers and business partners.
WhiteWall expects that all employees, customers and business partners are treated fairly and that their rights and privacy are respected. There shall be no different treatment because of gender, ethnicity, disability, origin, religion, age or sexual identity.
The company does not tolerate sexual harassment. Nor do we tolerate so-called mobbing. Signs of this include, in particular, defamation of an employee or his or her family, spreading rumors, threats, humiliation, insults, harassment, dishonorable or undignified treatment by superiors or colleagues, and deliberate withholding of information necessary for work. Affected persons have a right to be heard and taken seriously by contact persons such as supervisors or the human resources department.
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2. Avoiding Conflicts of Interest
2.1 Principles
Private and business interests must be strictly separated. Business connections or contacts may neither be used for personal or third-party advantage nor lead to a disadvantage for the company. In the event of the possibility or danger of conflicts of interest, employees must consult their supervisor in case of doubt. They must seek advice and assistance from their supervisor, the Human Resources department or the Compliance Officer. In this respect, every employee can also turn to the ombudsman.
In order to avoid conflicts of interest between the company and the private sphere, company employees should generally refrain from engaging WhiteWall business partners for private purposes. If it subsequently emerges that a business partner of WhiteWall has been engaged for private purposes, this must be reported immediately to the Compliance Officer.
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2.2 Conflicts of interest due to secondary activities
Employees of WhiteWall are obliged to have the exercise of any sideline activities approved by the Human Resources Department/Management Board. WhiteWall will refuse or revoke the approval for the exercise of a secondary activity if there are indications that the fulfillment of contractual tasks is impaired by the secondary activity and/or legal or labor law obligations are violated.
In order to exclude conflicts of interest, secondary employment for a competitor or another business partner is generally not permitted.
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2.3 Conflicts of interest due to shareholdings
Significant participations in other companies in the direct business environment (this includes in particular competitors, customers and suppliers) are only permitted with the express written approval of WhiteWall's management.
Significant financial interests of close family members in a competitor, customer or supplier must be reported.
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3. Handling of benefits received
Manufacturers and suppliers are to be selected solely on the basis of fair competition and taking into account the criteria of price, quality and suitability of their performance. This applies in the same way to other business partners and service providers. Employees of WhiteWall are prohibited from demanding, being promised or accepting benefits from third parties with whom WhiteWall seeks or maintains a business relationship.
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3.1. Gifts or other benefits
Other benefits are, for example, financial incentives, the free and reduced-price provision of objects for use, discounts, invitations to vacation trips or free tickets to special events. WhiteWall employees are generally not allowed to give gifts. If this is not possible for reasons of politeness, these gifts are to be handed over immediately to the superior, the personnel department or the compliance officer. They shall be used for donations in kind to charitable organizations or auctions among employees or for other company purposes. The offer of other donations must be reported to the responsible supervisor and documented. Deviations from this rule may be approved by management in exceptional cases.
The acceptance of cash is prohibited without exception.
Private travel associated with business trips or business trips may not be made at the expense of business partners or third parties. Such travel expenses must be settled in accordance with the applicable travel expense regulations without exception.
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3.2 Business meals and invitations
Business meals which, in terms of their occasion, nature, frequency and extent, constitute hospitality customary in business, i.e. which serve legitimate business purposes, are permissible if an invitation is extended voluntarily and within a reasonable framework of ordinary cooperation. However, any impression of improper influence on business decisions should be avoided. The necessary sensitivity in this respect is expected of all employees.
Invitations by business partners or service providers to other events (e.g. sporting or cultural events, in-house trade fairs, product information events, seminars, training courses, etc.) are only permissible if they are appropriate in terms of their nature and scope and, from an objective point of view, are customary in business. However, they require the approval of the supervisor in each individual case and in advance. In principle, the travel expenses and costs of accommodation incurred in this connection shall be borne by WhiteWall.
Members of the management may accept and issue invitations to events, including appropriate hospitality, if the organization is business-related and serves the interest of WhiteWall.
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4. Benefits to business partners
No financial or other benefits may be granted to business partners which could impair the business judgment of the recipient or lead to a conflict of interest.
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4.1 Gifts or other benefits to third parties
Other (in particular financial) benefits to business partners may not be offered, promised or granted. Gifts may be made in the usual context of a business relationship and to an appropriate material extent. They must not be perceived by the recipient as an advantage that could influence his or her business decisions in the sense of favoring the donor. Gifts may not exceed a value of € 50.00 per person in a calendar year. Any deviations from this rule must be approved in advance by the management and reported to the Compliance Officer.
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4.2 Hospitality
Business meals which, in terms of occasion, type, frequency and extent, constitute business entertainment, i.e. which serve legitimate business purposes, are permissible. Details are set out in the expense regulations.
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4.3 Conduct towards authorities and public officials
Holders of political offices and representatives of authorities or public institutions (public officials) are obliged to act in the public interest. Therefore, only appropriate and occasion-related gifts that comply with recognized social rules of courtesy and do not affect respect for the office or the political task are permissible (e.g. bouquet of flowers or bottle of wine on a birthday, on a service anniversary, on the occasion of leaving office).
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5. Donations/Sponsoring
WhiteWall participates in social and community life by making donations for charitable, social, cultural, sporting and scientific purposes to the extent customary in business. It does not make any donations, either directly or indirectly, to political parties or party-affiliated foundations.
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6. Combating white-collar crime and corruption
WhiteWall opposes all forms of corruption and related criminal acts. Corruption is strictly rejected and not tolerated by our company.
Corruption is colloquially understood as the abuse of entrusted power for personal self-interest. In criminal law, this includes the offenses of bribery, corruptibility, acceptance of benefits and granting of benefits (sections 331 - 335 of the German Criminal Code). Bribery and corruptibility in business dealings are also criminal offenses punishable by a fine or imprisonment of up to three years, in serious cases up to five years (Sections 299, 300 of the Criminal Code).
WhiteWall combats corruption preventively by means of suitable organizational measures and personnel regulations. In addition, the company does everything in its power to uncover corruption and related criminal acts and to prosecute them without regard to the person.
Employees who are exposed to an attempt at bribery must report this immediately to their supervisor and/or the compliance officer.
Employees who suspect corruption or other criminal acts or serious irregularities should report this suspicion.
In addition to their immediate supervisors, the contact persons for this are the Compliance Officer and the anti-corruption ombudsman appointed by the company. The ombudsman receives tips on possible corruption issues, which he treats as strictly confidential due to his duty of confidentiality as a lawyer. He will only pass on the facts to the Compliance Officer if the whistleblower expressly agrees to this. The identity of the whistleblower will not be disclosed unless the whistleblower requests it.
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7. Appearance in public
Involvement in a public or charitable institution, in associations or in public functions at municipal or supra-regional level, as well as the exercise of honorary offices, are generally welcomed by the company, provided that such involvement or honorary office does not jeopardize the fulfillment of contractual duties and is compatible with the position in the company. The acceptance of such commitments must be coordinated with the supervisor or the Human Resources department.
Company-relevant statements by executives to the public in interviews, lectures or publications must be consistent with the interests and objectives of the company in terms of their timing, setting and content. They must therefore always be coordinated with the management and, in the case of media contacts, additionally with the person responsible for corporate communications.
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8. Protection of company property and data, duty of confidentiality
Every employee of WhiteWall is obliged to handle company property responsibly and to protect it against loss, damage or misuse. In addition to the things provided for use, such as PCs, machines, etc., this also includes in particular intangible assets such as relevant data, trade secrets, patents and brands.
Company facilities or objects may not be used for private purposes or removed from the company's premises without the express consent of the supervisor. Details for laptops, telephones, etc. are governed by a separate work instruction on IT use.
Employees must maintain absolute secrecy about all company and business secrets both during the term of their employment and after its termination.
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9. Insider rules
As long as persons have insider information relating to WhiteWall, they may not trade in listed securities of the company. Insider information is all information which is not publicly known and which is capable of influencing the decision of an investor to buy, sell or hold a security (Sections 13, 14 WpHG).
WhiteWall maintains an insider directory in which all persons with potential insider knowledge are listed.
Insider information may not be passed on to persons outside WhiteWall without authorization (e.g. to journalists, financial analysts, customers, consultants, family members or friends). It must always be ensured that insider-relevant knowledge is kept under lock and key or secured in such a way that unauthorized persons cannot gain access to it.
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10. Acting in accordance with the Code of Conduct
10.1 Compliance with the Code of Conduct and consequences of violations
Each individual employee is responsible for complying with the provisions of this Code of Conduct in his or her daily work.
Managers have a special obligation to set a good example in complying with the principles and to be a role model for acting with integrity and loyalty through their own conduct. In particular, they must ensure that this Code of Conduct is implemented and brought to life in day-to-day business.
Anyone who violates this Code of Conduct must expect sanctions under labor law, up to and including termination/dismissal, irrespective of the person. If the company suffers damage as a result of violations, it will assert claims for damages/regress against the person or persons responsible within the scope of the legal possibilities. In the event of suspected criminal acts, criminal charges will always be filed.
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10.2 Contact for questions regarding the Code of Conduct
In the event of questions regarding the Code of Conduct or uncertainties as to the correct behavior, the discussion must be sought with the direct superior or the next higher superior. If this is not possible or not desired, the employees of the Human Resources department, the Compliance Officer and the members of the Works Council are available. In addition, any employee may also contact our ombudsman at no cost to him or her.
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Final provisions
Insofar as the employment contract or special guidelines contain more far-reaching provisions for specific individuals, these shall remain valid. The provisions of the respective employment contracts shall continue to apply. Relevant company regulations must be observed.
This Code of Conduct is to be further developed and, if necessary, improved on the basis of experience. It is therefore to be reviewed on an ongoing basis and revised in due course.
