20. Conduct that Complies with the Law and Policy

The company discloses which measures, standards, systems and processes are in place to prevent unlawful conduct and, in particular, corruption, how they are verified, which results have been achieved to date and where it sees there to be risks. The company depicts how corruption and other contraventions in the company are prevented and exposed and what sanctions are imposed.

We see our corporate values as the basis of all our actions. As an owner-managed family business that has been successfully developing cosmetic products for more than 15 years, we stand for our corporate values of passion, courage, trust, reliability, openness and responsibility. We also stand for loyalty - to our employees, to our business partners and to our locations. We assume responsibility and are committed to a high standard of ethics, fairness and transparency. These standards have been written down in our Code of Conduct and apply to cosnova GmbH and its locations as well as to all business partners. 
No specific risks arise from our business activities. On the one hand, our products are subject to strict regulations regarding product safety in accordance with the German Cosmetic Products Regulation (VO 1223/2009). On the other hand, our products, unlike pharmaceuticals, are in principle freely marketable. There are no specific risks, such as bribery of regulatory authorities. Our products are FMCG (fast moving consumer goods) in the entry-level price range. They are primarily sold at discount prices. The low margins in this segment offer little room for corruption. In contrast to the possible situation in the luxury cosmetics segment, there is no evidence that our products themselves are used for bribery; the brand image and low pricing rule this out. To date, there has been no additional compliance guideline to the Code of Conduct in the company, but we started developing one in 2018. In addition to the Compliance Guideline, a Compliance Box is planned that will allow employees to confidentially report violations of the Compliance Guideline. For compliance issues in general, the company's internal legal department is the point of contact. Internal communications and an online training platform can be used to raise awareness among employees at all management levels. Concrete goals or planned target achievement have not yet been defined in this area.