Compliance

Compliance at Ambulanz Mobile GmbH & Co. KG

Do the right thing …!

To sustainably secure the commercial success of Ambulanz Mobile GmbH & Co. KG, legal compliance and fair competition are paramount. This creates a basis of trust for our relationships with customers and business partners.
Ambulanz Mobile Code of Conduct

 

  1. Ful compliance with laws

The Company shall conduct its business and conduct its affairs in accordance with all laws, rules and regulations and with the Company’s high ethical standards.

The Company’s business and affairs shall be conducted in accordance with all laws, rules and regulations and with the Company’s high ethical standards.

  1. Working environment

The Company shall provide a safe and drug-free working environment in which employees are not exposed to harassment or discrimination based on race, color, creed, religion, gender, age, disability, national origin, descent, citizenship, military service, marital status, sexual orientation, or other discriminatory factors.

  1. Production of products

The company is committed to manufacturing safe and effective products. The Company manufactures its products in compliance with all applicable laws and regulations, including laws and regulations relating to environmental protection, occupational safety and health protection.

  1. Competitive practices

The company competes vigorously, fairly and in an ethical and legal manner in all business opportunities. The Company will comply with all antitrust and other laws regulating competition and trade in each country in which it does business. In addition, it does not collude with competitors regarding pricing, costs, production plans, business strategies or other proprietary or confidential information.

  1. Marketing and sales

The Company will truthfully disclose all information regarding its products and services and will comply with all applicable governmental and legal requirements governing the marketing and distribution of its products and services.

  1. Recording and reporting information

In view of the fact that accurate information is fundamental to fulfilling the legal and regulatory obligations of the company, all directors and employees must record and report all information accurately and truthfully. No employee shall, on behalf of the Company, sign or submit or permit others to sign or submit any document or statement that he or she knows is false or that he or she, in his or her sole discretion, believes to be false.

  1. Payments

The Company and its employees will not make improper payments to any government official, employee, customer, person or authority and will not solicit or accept improper payments from any supplier, customer or other person seeking to do business with the Company.

  1. Fair’s trading conduct

Every employee will always act fairly with respect to customers, suppliers, competitors, independent auditors and Company employees and will not gain any unlawful advantage, whether through manipulation, concealment of facts, misuse of privileged information, misrepresentation of important facts or other unfair practices.

  1. Confidential information

No employee will use confidential or proprietary information to obtain personal benefits or disclose to any third party any confidential or proprietary information obtained in the course of his employment with or through his relationship with the Company.

no employee will use confidential or proprietary information to obtain personal benefits or disclose to any third party any confidential or proprietary information obtained in the course of his employment with or through his relationship with the Company.

Confidential or proprietary information includes any non-public information that, if disclosed, could be useful to competitors or harmful to the company and its customers.

  1. Party Donations

The Company does not make donations to political parties or individuals, even in countries where such donations may be legal. However, it encourages employees to participate in community affairs and to perform their civic duties.

  1. Personal exploitation of business opportunities

Employees have a duty to the company to advance its legitimate interests whenever an opportunity arises to do so. Employees are prohibited from: (a) taking advantage of personal opportunities arising from the use of company property, information, or position within the company; (b) using company property, information, or position within the company to obtain personal benefits; and (c) acting in competition with the company.

  1. Conflicts of interest

No employee participates in activities or pursues interests outside the company that could lead to the following: Loss of the employee’s loyalty to the Company, impairment of the satisfactory performance of the employee’s duties, difficulty in the factual and effective performance of the task for the Company or measures and actions with a damaging or detrimental effect on the Company. Employees must promptly notify management in writing of any actual or potential conflict of interest in order to resolve such conflict.
A conflict of interest exists when an employee’s personal interests are, or appear to be, prejudicial to the interests of the Company. A conflict of interest may also exist if an employee or a member of his/her family receives inappropriate personal benefits due to his/her position within the Company.

  1. Protection and proper use of business equipment

Theft, negligence and waste have a direct impact on the company’s profitability. All employees take the necessary measures to protect the Company’s assets and ensure their efficient use for legitimate business purposes.

  1. Adherence
  2. The management is responsible for ensuring that employees understand and comply with the Code of Conduct. It is also responsible for creating a working environment in which compliance with the Code is expected and rewarded.
  3. Any violations of these policies and procedures should be reported immediately to management. The identity of the person making the report will always be preserved unless this information is needed to clarify the specific case. The reports can be made anonymously.
  4. Executives and employees are required at regular intervals to provide written confirmation of their understanding and compliance with these guidelines. In addition, they affirm that they are not aware of any violations of these guidelines and that they have properly reported all violations.
  5. The company/management will immediately investigate any alleged violations of these guidelines. Violations of any of the policies, retaliation against the person reporting a violation, or any other failure to comply with these policies will not be tolerated and will be subject to disciplinary action. Where appropriate, this may result in termination of employment.

 

 

Schönebeck, 03/2020

Compliance Management System

For the worldwide operating company Ambulanz Mobile GmbH & Co. KG, it is imperative to ensure an honest conduct in compliance with national and international laws and regulations as well as internal rules.

In addition to the existing guidelines in the company rules, the code of conduct and the data protection guideline, a compliance management system has been developed which helps to support compliance with all guidelines and laws. The goal of our Compliance Management System (CMS) is to protect Ambulanz Mobile GmbH & Co. KG and its employees from inappropriate and illegal behavior.

Compliance is the term for the observance of all laws and rules in a company.

Ambulanz Mobile GmbH & Co KG expects its managers and employees to comply with all laws and internal rules (regulated in the company rules, data protection guideline, code of conduct). All employees must familiarize themselves with the content of these guidelines and act accordingly. These guidelines form the basis for daily work.
Violations of the guidelines for integrity or other guidelines and regulations can, while maintaining proportionality, lead to consequences for the employment relationship and other legal consequences.

The management of Ambulanz Mobile fully supports all activities and efforts to ensure integrity and compliance with all laws.

Compliance Management System

The Compliance Management System of Ambulanz Mobile GmbH & Co KG consists of the Compliance Program “Prevention Identification Action”, which is based on the Code of Conduct. The Compliance Organization is headed by Mr. Hans-Jürgen Schwarz as Compliance Officer; the Compliance Officer is supported by a Compliance employee who assists in the further development of the Compliance Management System as well as in training and consulting.

The Compliance Program is to be implemented by the Compliance Organization through communication, control and improvements.

Compliance Program

The Compliance Program consists of three elements: prevention, identification and action. The following measures are designed to ensure compliance within the company.

Prevention

  • Code of Conduct and Internal Guidelines (Company Regulations, Privacy Policy)
  • management responsibility
  • Executives demonstrate compliance and communicate compliance to their employees.
  • Executives are responsible for ensuring compliance with the compliance guidelines in their respective areas of responsibility.
  • Training for all employees
  • regular training courses are required
  • The Purchasing and Sales divisions are particularly important in this respect.
  • Consulting
  • All employees can contact the Compliance Officer (CO) (alternatively Compliance employee) if they have any questions.
  • Agreement with distribution partners
  • Distributors sign an agreement to abide by our Code of Conduct
  • Compliance Campaign
  • Our customers are made aware of our Code of Conduct.
  • Notices that customers are not complying with the compliance guidelines are documented by our employees (business trip report)
  • Individual reporting and annual report to the Executive Board

Identification

  • “Black Box” or reporting via Compliance Officer/ Compliance Employee
    • Anonymous evidence of a compliance violation can be thrown into a box
    • Protection of internal whistleblowers from sanctions
  • Valuation of Business Partners
    • Risk assessment through credit reform of business partners
    • check in the course of business trip
  • Documentation
    • Gifts and invitations from and for customers/suppliers/business partners of Ambulanz Mobile are documented
  • Donations / Sponsoring
    • The Compliance Officer in cooperation with the Compliance checks employee donations and sponsoring before release
    • All donations and sponsorships are documented.

Action

  • Failure to comply with the guidelines is sanctioned and can lead to the loss of a job (maintaining proportionality).
  • Check all cases
    • Analysis of the note
    • Research
    • Execution of the verification
    • Create a report
    • Message to the management
    • Initiation of disciplinary measures together with the management

 

Schönebeck, 03/2020

To avoid legal risks, employees may contact their managers, the compliance officer with any questions they may have; of course you can do this anonymously, too, at:

Compliance Contact:
compliance@ambulanzmobile.de
Tel: 03928-4863-39900

In addition, there are also options for customers, supplier as well as any other external persons to ask compliance-relevant questions, also anonymously.