Code of Conduct
Our Mission
For us, the lawful conduct of Cofinity-X GmbH (hereinafter referred to as Cofinity-X) and of our employees, managers and members of the management is an indispensable component of responsible and sustainable corporate management and supervision (Corporate Governance).
We ensure that the corporate objectives of Cofinity-X are only achieved by legally and ethically sound means and that the public's trust in us is strengthened.
We are also aware of our role in society and our responsibility towards numerous stakeholders/interest groups, in particular our employees, customers, business partners and shareholders.
Scope of the Code of Conduct
The Code of Conduct applies to Cofinity-X and all employees and persons who are engaged in a similar way to employees. In addition to this Code of Conduct, there may be guidelines, manuals and work instructions for individual topics and areas that must also be observed.
Rules and Guidelines
Our Code of Conduct shows how we want to act and make decisions based on our values. It strengthens the ethical behaviour and integrity of our employees. Our values and the following rules and guidelines have the overriding goal of preventing any violations of legal requirements or at least making them significantly more difficult, reducing liability risks for Cofinity-X and all employees and avoiding financial and reputational damage. At the same time, they should protect the interests of our shareholders, too.
Everyone at Cofinity-X is responsible for implementing the values in their daily work. Cofinity-X ensures that these rules and guidelines are known, understood, and adhered to by all employees. We are all encouraged to be attentive and always speak up when we can improve something.
We operate the largest collaborative and open data ecosystem of partners and enable value generation and sustainability along the automotive value chain while complying with the Catena-X standards. We are aware of our responsibility to act globally. We comply with the applicable legal, social and environmental rules and standards and always act and make decisions in accordance with our internal business ethics. This also includes compliance with internationally recognized human rights both in our own area and within our supply chains. Our Code of Conduct forms the basis for our employees to work together. We also expect our business partners to adhere to these principles.
Compliance with national and international law
We comply with applicable international and national laws and regulations at all times.. Only this enables us to operate with sustainable business success.
Violations of applicable laws or regulations may have consequences for us as Cofinity-X as well as for the individual employee, such as criminal prosecution of the violation, consequences under labour law or damage to reputation.
We always investigate all indications of violations. Every infringement shall be remedied and appropriate consequences are drawn.
Stricter regulations than those set out in this Code of Conduct may apply in individual countries or sectors or to business partners. In such cases, the stricter applicable regulations must always be applied.
Integrity in business transactions
We are committed to fulfilling our social responsibility in accordance with our values in our daily business interactions and all corporate activities. For us, this means in particular
Corruption
Corruption in all its forms is contrary to our values at Cofinity-X. We categorically reject corrupt or otherwise unlawful behaviour, do not tolerate such behaviour under any circumstances and therefore have clear principles of conduct with regard to the granting and acceptance of invitations, gifts and other benefits.
Money laundering and terrorist financing
We do not allow ourselves to be misused for money laundering and terrorist financing and comply with all legal requirements for the prevention of money laundering and terrorist financing.
Antitrust and competition law
We do not tolerate any behaviour that violates antitrust law or any agreements with shareholders, competitors and suppliers that compromise fair competition. This includes price fixing, the allocation of customers or sales territories among competitors or other unfair competitive practices.
Foreign trade law
We take appropriate measures to ensure that transactions with third parties do not violate applicable economic embargoes, sanctions or trade, import and export control regulations.
Respect for intellectual property
We respect the intellectual property of third parties and only use third-party intellectual property if it is ensured that we have the corresponding rights of use, e.g. in the form of licences.
Furthermore, we would like to inform you about:
- the existence of your rights in relation to the processing of your personal data
- the data processing controller within the meaning of the data protection laws and, if applicable, our data protection officer(s)
Integrity in our organisation
In addition to integrity in our business dealings with our business partners, we are also obliged to know and comply with the basic laws, regulations and internal company rules within our own organisation. For us, this means in particular:
Respectful interaction with one another
Everyone has the right to be treated fairly, with dignity and respect. We are committed to diversity, inclusion and equal opportunities and stand for a working environment that is characterised by respect and tolerance and in which everyone is valued. Sexual harassment, discrimination, racism, bullying, abuse of power, intimidation and threats are not tolerated.
No one may be discriminated against on the grounds of ethnic origin, race, gender, religion or belief, disability, age or sexual identity.
Careful and proper handling of operating resources
We always handle operating resources of all kinds carefully and responsibly, e.g. work equipment, IT equipment or intellectual property. We only use resources for their intended business purposes and not for personal purposes that are inappropriate or prohibited.
Utilisation and security of IT systems
We actively help to protect the IT systems available to us from internal and external misuse. We take appropriate security precautions to protect our intellectual property and personal data.
We also take great care with the content of electronic communications and exchanged data.
Data protection
When collecting, storing, processing or transferring personal data from employees, business partners or other third parties, we exercise the utmost care and strict confidentiality and comply with the applicable legal provisions.
Dealing with trade secrets
We do not pass on business secrets to third parties without authorisation and protect them from unauthorised access. We also constantly monitor existing confidentiality agreements with our business partners. We handle our business affairs with the utmost care and only share critical business information with people who absolutely need to know this information.
Conflicts of interest
In our day-to-day work, business decision-making situations may arise in which the interests of Cofinity-X conflict with our personal interests. Conflicts of interest can lead to decisions no longer being made unbiased. We therefore immediately disclose any conflicts of interest that arise and work together to find a solution to resolve the conflict.
Ethical behaviour and social responsibility
Health and safety at work
We comply with the laws and regulations on occupational safety and health in the workplace and ensure a healthy and hazard-free working environment.
Human rights
We respect internationally recognized human rights. These include the five pillars of the International Labour Organization (ILO) core labour standards, i.e. the rights to freedom of association and collective bargaining, compliance with the rules and regulations on occupational health and safety and the prohibition of child labour, forced labour and slavery in all forms, as well as the prohibition of unequal treatment in employment.
Environmental protection and sustainability
We comply with all applicable environmental regulations and strive to increase resource and energy efficiency in the production and distribution of our products and services and to minimise any negative impact on the environment. We always procure and utilise resources such as energy and water responsibly.
Standard of behaviour for decisions
We ask our employees to ask themselves the following questions in every decision they make in connection with their work for Cofinity-X in order to uphold our corporate values:
- Is my decision lawful and in line with Cofinity-X's corporate values and the requirements of this Code of Conduct?
- Is my decision based on responsible professional judgement?
- Would I stand by my decision if it were made public?
- Will my decision preserve the good reputation of Cofinity-X?
Counselling of employees
Our employees can also contact the Cofinity-X Compliance Officer at any time by e-mail at compliance@cofinity-x.com with any doubts or questions about the Code of Conduct and the prevention of violations and obtain advice from him via this helpline. Only the Compliance Officer of Cofinity-X has access to these e-mails.
Reporting violations
If our employees suspect that applicable relevant legal requirements or internal guidelines of Cofinity-X are being violated, they are required to report the suspected case to the Compliance Officer of Cofinity-X immediately.
The Cofinity-X whistleblower system can also be used for anonymous submission of information by our employees and third parties under the following link:
https://cofinity-x.integrityline.app
Entry into force
The Code of Conduct comes into force on 13th March 2024.