Code of Conduct

1. Introduction/Preamble

Stürmer Maschinen GmbH is committed to ecologically and socially responsible corporate governance. We expect the same behaviour from all our business partners. We also expect our employees to observe the principles of ecological, social and ethical behaviour and to integrate them into the corporate culture. Furthermore, we strive to continuously optimise our entrepreneurial activities, our products and our services in terms of sustainability and ask our business partners to contribute to this in terms of a holistic approach.

Our Code of Conduct is based on national laws and regulations as well as international conventions such as the United Nations Universal Declaration of Human Rights, the Guidelines on Children's Rights and Business Conduct, the United Nations Guiding Principles on Business and Human Rights and the International Labour Standards of the International Labour Organization. We expect our business partners to comply with all relevant laws and regulations as well as the requirements of national and international standards.

2. Principles of our entrepreneurial conduct

a) General principles

Scope of validity

Our Code of Conduct represents binding rules that must be observed by every employee of our company. The Code of Conduct is the basis and guideline for coping with ethical and legal requirements in daily work. In particular, the members of the Executive Board and all managers bear the responsibility for actively implementing these rules. They have to serve in a role model function in every respect. Every employee can turn to his or her line manager or the Executive Board with questions and comments in this regard.

Integrity - Credibility – Transparency

We conduct our business actions and decisions in accordance with universally agreed ethical values, in particular integrity, credibility and respect for human dignity. We promote transparency, responsible management and control in the company in an appropriate manner.

Compliance with the laws

Our company and all our employees observe the laws and other legal regulations of the countries in which we operate. This particularly refers to the regulations of national, European and international product safety, machinery, waste and chemical legislation as well as embargo, customs and export control regulations.

Supply chain

We have formulated and published a separate Code of Conduct for our suppliers. We expect them to comply with the principles of the Code of Conduct, oblige them to implement it and encourage them to act accordingly in their supply chains.

Consumer protection

As far as consumer interests are concerned, our company complies with the regulations for the protection of consumers.

b) Conduct towards competitors, business partners and third parties

Competition and antitrust law

Our employees are obliged to comply with the rules of fair competition. In particular, any agreement or coordinated action with competitors on the following topics is prohibited:

  • Pprices and price components
  • Terms and conditions
  • Customers
  • Delivery areas
  • Quotas and capacities
  • Agreed market exits
  • Coordination on planned innovations
  • Boycotts

Our company respects the rules of fair and open competition and does not enter into any agreements that influence competition in an improper manner.


Our company explicitly opposes any form of corruption domestically or abroad and avoids even the appearance of trying to influence business decisions through unfair business practices. No employee may use the company's business connections to his or her own advantage or to the disadvantage of others. This means in particular that no employee grants or accepts unauthorised private advantages in business dealings, e.g. money, material assets, services, which are suitable for influencing an appropriate decision. Every employee of the company is obliged to seek advice or assistance in the event of suspicions or legal doubts regarding the occurrence of corruption or economic crime. Advice or assistance can be obtained from the employee representative committee (MAV) and/or the management.

Calls for tender

If a contract is awarded on the basis of a formal call for tenders, our employees will neither discuss nor coordinate offers with other tenderers. This applies to both public and restricted tenders and irrespective of whether it is an award procedure by the public sector or by a private entity.

Granting and accepting of benefits, invitations and gifts

Invitations, such as to business dinners or events, which are in accordance with recognised business practices and appropriate, may be offered or accepted if they are not intended to give undue preference. The same applies to the acceptance or granting of gifts. If there is any doubt as to the existence of an objective reason or the appropriateness of a gift, the employee must first ask the management. This issue is regulated internally.

Donations and sponsorship

Donations and sponsoring shall only be made on a voluntary basis and without expectation of any benefit in return. Donations and sponsorship must not be undertaken to promote decisions in the interest of the company in a hidden manner. The donation must be transparent. The recipient of the donation and the specific use by the recipient must be known. It must be possible to render a true account of the reason for the donation and the intended use at any time. Remuneration similar to donations must be avoided. Donation-like remunerations are benefits which only appear to be granted as remuneration for a service, but whose value clearly exceeds the value of the service.

Officials - Political parties - Mandate holders - Advisors – Agents

The granting of advantages of any kind to any public official or other functionary as well as to representatives of state institutions, including indirectly through third parties, is prohibited, regardless of the value of such advantages. In the case of donations to parties and political organisations as well as to mandate holders and candidates for political offices, the respective applicable laws shall be complied with. The commissioning of consultants, agents and other contract intermediaries may not be used to circumvent ban on bribery.

Money laundering

Our company does not tolerate money laundering. All employees are required to strictly comply with anti-money laundering laws. They must also immediately report any suspicious forms of payment or other transactions that may indicate money laundering to management.

Tax law - Customs law - Foreign trade law

Our company truthfully submits tax declarations and statements. All goods subject to customs duties are duly cleared by us. Our company consistently complies with the legal requirements for export control and customs from foreign trade and customs law and ensures their proper implementation. The company expects its suppliers to provide export control and foreign trade data in a qualified and timely manner and to implement sufficient foreign trade and customs law standards for security in the supply chain.

Avoidance of conflicts of interest

Our company expects loyalty from its employees. We take care to ensure that our employees do not find themselves in situations where their personal or financial interests conflict with those of our company or our business partners. Employees of our company shall immediately report any personal interest that may exist in connection with their work to their superiors. Our employees are prohibited from managing or working for a company that is in competition with our company. This also applies to the involvement of a close relative or life partner.

c) Dealing with information

Company and business secrets

Our employees are obliged to maintain confidentiality about company and business secrets and other internal matters. This applies accordingly to information about contractual partners and customers that is not publicly accessible. This confidentiality obligation shall continue to apply after the termination of the employment relationship.

Data protection

All our employees must strictly comply with the data protection regulations of the EU General Data Protection Regulation and national and international data protection laws. In particular, it is prohibited to process, disclose, make accessible or otherwise use protected personal data without authorisation for a purpose other than the legitimate fulfilment of the respective task. This obligation to comply with data protection regulations shall continue to apply even after leaving the company.

Duty of truthfulness

Reports and other written documentation are to be written correctly and truthfully by our employees. This applies regardless of whether they are internal or external documents. Relevant records and supporting documents must be based on the principles of proper accounting and must always be complete and correct.

d) Principles of social and environmental responsibility

Social responsibility - social engagement

Social responsibility is an indispensable part of our value-oriented corporate governance and an essential factor for our sustainable corporate success. Our company contributes to the social and economic development of the country and region in which we operate.

Human Rights - Child Labour

The company respects and supports internationally accredited human rights. In this context, we are also in constant dialogue with our suppliers to avoid our products containing raw materials from conflict regions. Bans on child labour and forced labour in any form are complied with without exception.

Equal opportunities - non-discrimination

Our company encourages equal opportunities for our employees.  Discrimination against employees and third parties is not tolerated. Our company rigorously counteracts unacceptable treatment of employees, in particular sexual or verbal harassment.

Employees' rights - Work safety - Health protection

Employees' rights are fully respected by us to the extent legally permissible under national regulations. Our company observes the applicable national laws and labour standards with regard to appropriate remuneration and maximum working hours. This also includes compliance with all provisions of the regulations on a general minimum wage in Germany. Our company ensures fair working conditions in general. The prescribed work safety and health protection at the workplace is ensured within the framework of national regulations.

Environmental protection - Climate protection

Sustainable environmental and climate protection as well as resource efficiency are important corporate values for us. Both in the development of new products and services and in the distribution of our products and services, we ensure that any impact they may have on the environment and the climate is kept as low as possible and also that our products make a positive contribution to environmental and climate protection for our customers. Every employee has the responsibility to treat natural resources with care and to contribute to the protection of the environment and climate through his or her individual behaviour.

e) Compliance with the Code of Conduct

Communication - Control - Notification of violations

We familiarise our employees with the contents regulated in this Code of Conduct and explain the obligations arising therefrom. We also communicate the principles of the Code of Conduct to our business partners. We also undertake to regularly monitor compliance with the Code. Every employee of the company is required to report any actual, potential or threatened violations of laws, internal regulations and this Code of Conduct that he or she observes to the management without delay. Reports of a violation of this Code will be treated strictly confidentially and will not have any negative consequences for the reporting employee, unless an untrue fact was intentionally alleged.

Processes - Guidelines – Instructions

The behavioural requirements set out in this Code of Conduct are binding on the company's employees as part of their employment contract and must therefore be complied with. The company shall take all necessary steps to implement the basic values and requirements contained in this Code of Conduct through appropriate organisational measures as well as adequate instructions, processes and guidelines in all units of the company.

Consequences of infringements

Violations of the Code of Conduct and legal provisions may, depending on their severity, result in consequences under labour and liability law and may also lead to criminal prosecution.