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 reject any form of corruption and all activities that infringe laws against money laundering. Fairness in competition is indispensable for us. This means anti-competitive agreements and any abuse of a market-leading position are not in line with the business policies of HOPSTEINER and its business partners.  

The following statement is written into our Code of Conduct:  

Our decisions and all purchasing and sales activities are always based on factual criteria and not influenced by personal interests. This high transparency also applies to how we deal with gifts. We fundamentally reject the acceptance and offering of incentives of a financial or material nature. Under no circumstances are gifts or other benefits to be solicited from us or their acceptance tolerated. Gifts from business partners and benefits of other kinds offered or made available to us by business partners that go beyond a customary measure of expression of hospitality are to be declined as a matter of principle. This applies in particular when the gift influences a business relationship in an unacceptable manner or risks causing damage to our professional neutrality. In the event of doubt, the executive management is to be informed so that any infringements can be met with the appropriate sanctions.  

To create trust, our business processes must be recorded in a comprehensible way and performed in accordance with the generally applicable rules of orderly business operations. All contact with internal and external partners is transparent and fully traceable. To this end, we ensure that the services of advisers, agents, or intermediaries are remunerated in compliance with statutory regulations. Informal conversations without documentation therefore are in no way binding and are treated as non-existent.  

We respect the confidentiality of information and business secrets and use data relating to these only internally and for the processing of mutual business contacts and employment relationships. Respecting the confidentiality of information and commercial secrets is a fundamental component of our business relationships. We expect our business partners to observe and apply the laws applicable to the protection of personal data.

Compliance with regulations is insured by the comprehensive control of all incoming invoices, payments and business processes by the executive management, accounts department, and the employees responsible for them. The executive management and the sustainability officer are responsible for the topic of compliance. Making employees and managers aware of these issues is done as part of regular employee meetings.  

In terms of our business activities and in the light of the measures identified above, we see no risks to and therefore no negative impacts on the issues of corruption and bribery. In the topic “Conduct that complies with the law and policy,” the company therefore has no management concept because this has been categorized as not material for company activities.