Compliance Code

Our company
Schleicher Fahrzeugteile GmbH & Co. KG is a medium-sized family business with its headquarters in Penzberg and production facilities in Munich and Penzberg. Both plants are currently being merged into a central production and development site in Penzberg; this process is to be completed in 2023. Today, Schleicher Fahrzeugteile counts over 200 employees.

Standards:
Our growth in new markets and countries also means that we meet the standards and guidelines applicable to our relations with our business partners. For us, this code of ethics includes compliance with the national and international standards, laws and regulations in the countries with which we cooperate. Our compliance code is published on our company homepage.

Principles:
All employees at Schleicher Fahrzeugteile follow these principles and take responsibility for adherence to them. The guidelines deriving from them and the associated documents are published in our internal integrated management system (SIMS) and can be accessed by employees at all times. New employees are issued with a copy together with their contracts.

Our business partners :
Customers, suppliers, competitors, consultants and other business partners

Scope of validity :
Our principles apply world-wide and are the basis for our code of conduct.

RESPONSIBILITY

It is our responsibility to ensure that our employees work in a safe and healthy environment.

Culture of management :
Our managerial staff set a good example: our fair culture of discussion and the respect we show in our interaction demonstrate our esteem for our employees, colleagues and business partners.

We place our trust in our employees.
We believe that all of our management, managerial staff and employees share the responsibility for adherence to the guidelines.

We respect human dignity.
We show fairness and respect in our relationships with each other. We do not tolerate any form of discrimination or harassment. A special guideline (anti-discrimination agreement) accessible to all employees refers to the Anti-Discrimination Act (AGG and §61b ArbGG) and the possibility of complaining to the works council (anti-discrimination body) or alternatively to the Human Resources department.

We reject every form of forced labour/modern slavery.
No force may ever be used to make an employee work.

Prohibition of child labour
We do not tolerate any child labour or any other exploitation of minors. We implement the special protection regulations of the Youth Employment Protection Act (JArbSchG) valid in the Federal Republic of Germany.

Social responsibility :
Schleicher Fahrzeugteile supports the work done with children and young people by non-profit sports clubs and games/sports events in Munich and Penzberg via donations/sponsorship – demonstrating our internal principles to the world at large and making our contribution to society.

CO-DETERMINATION :

The works council, consisting of freely elected employee representatives and forming a link between the management and the workforce, is the contact point for all issues and complaints from employees at Schleicher Fahrzeugteile GmbH & Co. KG. There is no collective bargaining coverage; however, employees are free to organize themselves in a union (freedom of association).

The co-determination rights as laid down in the German Works Constitution Act (BetrVerfG) enables the works council to be involved in company agreements, including the organization of working hours and overtime, the payroll and the structure of supplements and bonuses. All company agreements are published on a notice board and in the internal communication system.

Particular attention is paid to our disabled persons and our trainees. These groups are supported by their own representatives (severely disabled representative SBV/ youth and trainee representative JAV) together with the works council.

Remuneration and social benefits
In addition to wages and salaries, Schleicher Fahrzeugteile also offers corresponding social benefits.

ENVIRONMENT

We aim to leave an intact environment for the next generation.

We make sparing and efficient use of our resources of energy, steel and operating materials and equipment. Our company management and the whole of the workforce undertake to comply with statutory regulations and our internal guidelines.

Schleicher Fahrzeugteile has both an environmental management system for the implementation of environmental policy and environmental goals (DIN EN ISO 14001:2015) and an energy management system (DIN EN ISO 50001:2018) for recording and reducing the amount of energy required by in the company. The currently valid certificates can be accessed at all times on the company website. A dedicated environmental and energy management officer, who reports directly to the management, is responsible for planning and monitoring the functionality and effectiveness of the systems.

PRIVACY POLICY

The protection of the personal data of our employees and business partners is implemented within the statutory framework of the GDPR valid in the Federal Republic of Germany. The corresponding privacy policy declarations are published on our homepage. The contact details of our external data protection consultant can also be found there.

Any disclosure of information is covered by data protection regulations and confidentialitiy agreements.

FAIR COMPETITION & ANTITRUST LEGISLATION

Our employees must maintain the interests of the company and may not use their professional status in relation to any business partners to their own advantage or to the advantage of a third party. We oppose any price fixing and market sharing agreements with competitiors.

GIFTS/INVITATIONS

Our employees may not offer or accept any gifts or invitations given with the intention of influencing business relations. Even the appearance of illicit influence must be avoided.

Acceptance of gifts
Gifts from business partners must be refused. This does not apply to small gifts (tokens of appreciation) with a value of no more than € 35,00 per year. The acceptance of gifts with a value of over € 35,00 is possible in certain circumstances, if it corresponds to the customs of hospitality within the relevant country. In such cases, the gift may be accepted.

Gifts in the form of money
The acceptance of gifts in the form of money is strictly prohibited.

Acceptance of invitations
Invitations from business partners may be accepted if the occasion and extent of the invitation are appropriate. The invitations must be within the limits of normal business hospitality and must not violate any laws or our ethical principles. Invitations to business meals may only be accepted if they are in connection with promoting and maintaining external business relationships. If there is any doubt, employees should contact their supervisor/manager.

CORRUPTION, EXTORTION, BRIBERY & CONFLICTS OF INTEREST

We tolerate neither corruption, extortion, bribery nor conflicts of interest – and this is a prime concern at Schleicher Fahrzeugteile. Any infringement of this ruling must be reported to the Works Council or to our management.

CONSEQUENCES OF ANY FAILURE TO COMPLY

Any violations of these guidelines will lead to disciplinary consequences for the employees and business partners involved.

Penzberg, den 10.01.2023

Schleicher Fahrzeugteile GmbH & Co. KG
Executive management