Magnus Technology

Magnus Technology Code of Conduct Guidelines

A. Basic Behavioral Requirements

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.

A.1. Responsibility for the Image of Magnus Technology

To a substantial degree, the image of Magnus Technology 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 Magnus Technology 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.

A.2. Mutual Respect, Honesty, and Integrity

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.

A.3. Management, Responsibility, and Supervision

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:

  1. 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).
  2. 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).
  3. The manager must see to it that compliance with provisions of the law is monitored on a constant basis (duty of monitoring).
  4. The manager must clearly communicate to the employees that violations of the law are disapproved of and will have employment consequences.

B. Treatment of Business Partners and Third Parties

B.1. Abiding by Fair Competition and Anti-Trust Legislation

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.

B.2. Offering and Granting Advantages

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.

B.3. Demanding and Accepting Advantages

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.

B.4. Special Rules for Awarding Contracts

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:

  • 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.
  • There must be no unfair discrimination for or against any suppliers in their competition for contracts.
  • 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.
  • Gifts from business partners must be refused and returned unless they are occasional gifts of insignificant value.
  • 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 Magnus Technology.

B.5. Donations

The following rules apply to granting donations:

  • Applications for donations submitted by individuals are to be rejected in principle.
  • Payments to private accounts are inadmissible.
  • In no case may the grant be made to any person or organization that would damage our reputation.
  • 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.
  • The donations should be tax-deductible.

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.

C. Avoiding Conflicts of Interest

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.

C.1. Prohibition of Competition

It shall be prohibited to operate a company which competes in whole or in part with Magnus Technology or any of its subsidiaries.

C.2. Sideline Work

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.

D. Handling of Company Property

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.

E. Handling of Information

E.1. Records and Reports

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.

E.2. Confidentiality

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.

E.3. Data Protection and Data Security

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. 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.

F. Elimination of Child Labor, Environment, Safety, and Health

F.1. Elimination of Child Labor

Every manager and every employee will ensure that no labor is performed by children or minors within Magnus Technology, its suppliers, business partners or customers, thereby following the Declaration on Fundamental Principles and Rights at work, 1998. Magnus Technology managers and employees will actively support all efforts to eliminate any child labor.

F.2. Environment and Technical Safety

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.

F.3. Work Safety

Responsibility vis-à-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.

G. Complaints and Comments

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.

H. Implementation and Controlling

The management of Magnus Technology, 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 Magnus Technology’ companies on a regular basis. This shall be done in accordance with the national procedures and legal provisions in question.

Appendix

Conventions and Recommendations of international organizations

Besides the laws and regulations in each country there is a number of Conventions and Recommendations from international organizations. They are primarily addressed to Member States and not directly to companies. Nonetheless, they are important guidelines for the conduct of multinational companies and their employees. Magnus Technology therefore emphasizes the importance of being globally in accordance with these guidelines. Magnus Technology also expects this from its suppliers and business partners. Hereafter we list the most relevant Conventions of this kind:

  • Universal Declaration of Human Rights, UNO 1948, and European Convention for the Protection of Human Rights and Fundamental Freedoms, 1950;
  • ILO (International Labour Organisation) Tripartite Declaration of Principles concerning Multinational Enterprises and Social Policy, 1997 and ILO Declaration on Fundamental Principles and Rights at work, 1998 (specially with following issues: elimination of child labor, abolishment of forced labor, prohibition of discrimination, freedom of association and right to collective bargaining);
  • OECD (Organisation for Economic Co-operation and Development) Guidelines for Multinational Enterprises, 2000;
  • “Agenda 21” on sustainable development (final document of the basic UNconference on environment and development, Rio de Janeiro 1992).