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A.1.
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Basic Behavioral Requirements
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Observance of the law and the legal system is a fundamental principle for our
Company. Every employee shall obey the laws and regulations of the legal systems
within which they are acting. Violating the law must be avoided under all circumstances,
especially violations punishable by jail, monetary penalties, or fines.
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A.2.
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Responsibility for the Image of LED Lease
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To a substantial degree, the image of LED Lease is determined by our actions and
by the way each and every one of us presents and conducts himself/herself. Inappropriate
behavior on the part of even a single employee can cause the Company considerable
damage.
Every employee should be concerned with the good reputation of LED Lease in each
country. In all aspects of performing his/her job, every employee must focus on
maintaining the good reputation of, and respect for, the Company.
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A.3.
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Mutual Respect, Honesty, and Integrity
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We respect the personal dignity, privacy, and personal rights of every individual.
We work together with women and men of various nationalities, cultures, religions,
and races. We tolerate no discrimination and no harassment or offence, be it sexual
or otherwise personal.
We are open and honest and stand by our responsibility. We are reliable partners
who make no promises we cannot keep. These principles shall apply to both, internal
cooperation and conduct towards external partners.
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A.4.
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Management, Responsibility, and Supervision
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Every manager bears responsibility for the employees entrusted to him/ her. Every
manager must earn their respect by exemplary personal behavior, performance, openness,
and social competence. He/she shall set clear, ambitious, and realistic goals, lead
by trust and confidence and leave the employees as much individual responsibility
and leeway as possible. Every manager shall also be accessible in case employees
wish to discuss a professional or personal problem.
Every manager must fulfill duties of organization and supervision. It will be the
responsibility of every manager to see to it that there is no violation of laws
within his/her area of responsibility which proper supervision could have prevented
or rendered more difficult. The manager still remains responsible, if he/she delegates
particular tasks.
The following shall apply in particular:
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1.
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The manager must carefully select the employees for their personal and professional
qualifications. The duty of care increases with the importance of the obligation
to be entrusted to the employee (duty of selection).
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2.
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The manager must formulate the obligations in a precise, complete, and binding manner,
especially with a view to compliance with provisions of the law (duty of instruction).
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3.
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The manager must see to it that compliance with provisions of the law is monitored
on a constant basis (duty of monitoring).
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4.
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The manager must clearly communicate to the employees that violations of the law
are disapproved of and will have employment consequences.
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B.
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Treatment of Business Partners and Third Parties
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B.1.
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Abiding by Fair Competition and Anti-Trust Legislation
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Every employee is obligated to abide by the rules of fair competition.
Employees and competitors may not have talks in which prices or capacities are arranged.
It is also inadmissible to enter into an agreement not to compete with a competitor;
to submit false offers for bidding; or to divide up customers, territories, or production
programs.
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B.2.
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Offering and Granting Advantages
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No employee may directly or indirectly offer or grant unjustified advantages to
others in connection with business dealings, neither in monetary form nor as some
other advantage. Client gifts to business partner employees must be selected so
as to avoid any appearance of bad faith or impropriety in the mind of the recipient.
In cases of doubt, the recipient should be asked to obtain prior permission for
the gift from his/her supervisor. Gifts must not be made to public officials or
other civil servants. Employees concluding contracts with consultants, intermediaries,
agents, or comparable third parties must see to it that these also offer or grant
no unjustified advantages.
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B.3.
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Demanding and Accepting Advantages
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No employee may use his/her job title to demand, accept, obtain, or be promised
advantages. This does not apply to the acceptance of occasional gifts of insignificant
value, but any other gifts must be refused or returned.
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B.4.
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Special Rules for Awarding Contracts
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Any bidder for a contract expects us to examine his/her bid fairly and without prejudice.
Employees whose work involves the awarding of contracts must particularly abide
by the following rules:
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The employee must inform his/her supervisor of any personal interest he/she could
possibly have in connection with the execution of his/her professional duties.
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There must be no unfair discrimination for or against any suppliers in their competition
for contracts.
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Invitations from business partners may only be accepted if the occasion and scope
of the invitation are appropriate and if refusing the invitation would be discourteous.
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Gifts from business partners must be refused and returned unless they are occasional
gifts of insignificant value.
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No employee may have private contracts fulfilled by companies with which he/she
has company business dealings if he/she could derive any advantage therefrom. This
is particularly applicable if the employee exercises or is capable of exercising
a direct or indirect influence upon having that company receive a contract from
LED Lease B.V or one of its subsidiaries.
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B.5.
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Donations
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The following rules apply to granting donations:
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Applications for donations submitted by individuals are to be rejected in principle.
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Payments to private accounts are inadmissible.
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In no case may the grant be made to any person or organization that would damage
our reputation.
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The donation must be transparent. The recipient of the donation and the recipients’
actual use thereof must be known. One must at any time be able to justify the reason
for the donation and its use for the purpose served thereby.
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The donations should be tax-deductible.
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Quasi-donations are prohibited as violating the principles of transparency. Quasidonations
are grants which are intended to look like compensation for a particular performance.
However, the compensation is substantially greater than the value of the performance.
At least in part, it is thus a matter of a grant for other purposes.
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C.
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Avoiding Conflicts of Interest
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The Company considers it important to prevent its employees from succumbing to conflicts
of interest or of loyalty in their professional activities. Such conflicts can come
about if an employee is active on behalf of, or has interests in, another company.
The following rules thus apply for all of us.
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C.1.
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Prohibition of Competition
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It shall be prohibited to operate a company which competes in whole or in part with
LED Lease B.V. or any of its subsidiaries.
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C.2.
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Sideline Work
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Anyone who intends to begin paid sideline activities must inform his/her immediate
superior beforehand in writing. Permission for such activities may be denied if
it leads to a decrease in work performance, contradicts the employee's duties within
the Company, or threatens to present a conflict of interest. Exceptions are occasional
writing activities, lectures, and comparable occasional activities.
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D.
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Handling of Company Property
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The devices and equipment in offices and workshops (such as telephones, copying
machines, PCs, software, Internet/Intranet, machines, tools) are to be used only
for company business. Exceptions, and payment if applicable, can be agreed upon
locally. In no case may any information be retrieved or transmitted which incites
racial hatred, glorification of violence, or other criminal acts, or contains sexually
offensive material which is sexually offensive within the respective cultural background.
No employee shall be permitted without the consent of his/her superior to make records,
databases, video and audio recordings, or reproductions unless this is directly
due to company business.
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E.
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Handling of Information
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E.1.
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Records and Reports
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Open and effective cooperation requires accurate and truthful reporting. This applies
equally to the relationship with investors, employees, customers, and business partners,
as well as with the public and all governmental offices.
Any records and reports produced internally or distributed externally must be accurate
and truthful. According to proper bookkeeping principles, data and other records
must always be complete, correct, and appropriate in terms of time and system. The
requirement of truthful statements applies to expense accounts as well.
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E.2.
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Confidentiality
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Confidentiality must be maintained with regard to internal corporate matters which
have not been made known to the public. As an example, this includes details concerning
the Company's organization and equipment, as well as matters of business, manufacturing,
research and development, and internal reporting figures. The obligation to maintain
confidentiality shall extend beyond the termination of the employment relationship.
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E.3.
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Data Protection and Data Security
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Access to the Intranet and Internet, worldwide electronic information exchange and
dialogue, electronic business dealings—these are crucial requirements for the effectiveness
of each and every one of us, and for the success of the business as a whole. However,
the advantages of electronic communication are tied to risks in terms of personal
privacy protection and data security. Effective foresight with regard to these risks
is an important component of IT management, the leadership function, and also the
behavior of each individual. Personal data may only be collected, processed, or
used insofar as this is necessary for pre-determined, clear, and legitimate purposes.
High standards must be ensured with regard to data quality and in technical protection
against unauthorized access.
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The use of the data must be transparent for those concerned; and the rights of the
latter must be safeguarded with regards to information and correction and, if applicable,
to objection, blocking, and deletion.
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F.
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Elimination of Child Labor, Environment, Safety, and Health
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F.1.
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Elimination of Child Labor
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Every manager and every employee will ensure that no labor is performed by children
or minors within LED Lease, its suppliers, business partners or customers, thereby
following the Declaration on Fundamental Principles and Rights at work, 1998. LED
Lease managers and employees will actively support all efforts to eliminate any
child labor.
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F.2.
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Environment and Technical Safety
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Protecting the environment and conserving its resources are high-priority targets
for our Company. Already at the product development stage, environmentally friendly
design, technical safety, and health protection must be fixed targets. Every employee
in his/her job must contribute to an exemplary performance in this field.
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F.3.
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Work Safety
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Responsibility vis-a-vis employees and colleagues requires the best possible accident
prevention measures. This applies both to the technical planning of workplaces,
equipment, and processes and to safety management and personal behavior in the everyday
workplace. The work environment must conform to the requirements of health oriented
design. Every employee must constantly be attentive to safety.
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G.
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Complaints and Comments
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Any employee may lodge a personal complaint with his/her supervisor, the Personnel
Manager, or some other person/unit designated for this purpose, or indicate circumstances
which point to a violation of the Code of Conduct Guidelines. The matter will be
investigated thoroughly. The corresponding measures will be implemented if appropriate.
All documentation will be
kept confidential. No reprisal of any kind will be tolerated. Employees should exhaust
the internal possibilities of mediation.
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H.
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Implementation and Controlling
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The management of LED Lease B.V., and its subsidiaries throughout the world shall
actively foster the widespread distribution of the Code of Conduct Guidelines and
see to it that they are implemented permanently. Compliance with the law and observance
of the Business Conduct Guidelines shall be monitored worldwide in all LED Lease'
companies on a regular basis. This shall be done in accordance with the national
procedures and legal provisions in question.
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