1. Scope
These guidelines apply to:
- All employees, trainees, interns and managers of NERAK GmbH Fördertechnik
- All sites, subsidiaries and branches
- External partners, insofar as they act for or on behalf of NERAK GmbH Fördertechnik
2. Objectives of Compliance Management
- Ensuring adherence to laws, standards and internal regulations
- Preventing corruption, fraud, money laundering and antitrust violations
- Promoting a culture of integrity and transparency
- Protecting the company from legal, financial and reputational risks
3. Fundamental Principles
- Legality: Strict compliance with all legal requirements
- Integrity: No compromise on ethical standards
- Transparency: Disclosure of conflicts of interest and risks
- Responsibility: Every employee is responsible for compliance
4. Key Compliance Areas
4.1 Anti-Corruption
- Prohibition of any form of bribery or improper advantage
- Acceptance and giving of gifts only with approval from the HR Management
- Sponsorships and donations require approval from the Management Board
4.2 Conflicts of Interest
- Disclosure of private business relationships that may cause conflicts
- Prohibition of secondary employment without prior approval
4.3 Antitrust Law and Fair Competition
- No price-fixing, market sharing or anti-competitive behaviour
- Participation in industry meetings only after prior compliance review
4.4 Data Protection and Information Security
- Compliance with the GDPR and internal data protection policies
- Confidential information must not be disclosed without authorisation
- Use of IT systems strictly in accordance with security guidelines
4.5 Export Control and Sanctions
- Verification of all exports against embargoes, sanctions lists and dual-use items
- Approval required for exports to sensitive countries
4.6 Occupational Safety and Environmental Protection
- Compliance with occupational health and safety regulations
- Implementation of all environmental requirements
- Reporting safety risks through defined channels
5. Reporting Obligations and Whistleblowing System
- Every employee is required to report violations immediately.
- Reports may be submitted confidentially and anonymously via the whistleblowing system (NERAK email).
- Whistleblowers are protected from retaliation.
6. Sanctions for Violations
- Employment-related measures (from warnings to dismissal)
- Civil and criminal consequences
- Claims for damages in cases of culpable behaviour
7. Documentation and Monitoring
- All relevant processes are documented (e.g. approvals, reviews, audits)
- Annual compliance report to the Management Board by HR Management
- Continuous improvement within the compliance management system