Compliance – acting in accordance with our values and the law

As an industrial enterprise and an employer, we are aware of our significant responsibility towards our neighborhood, the environment, customers and business partners as well as our employees.

In order to fulfill this responsibility, we have developed common guiding principles and defined them in our Code of Conduct.

The Code of Conduct summarizes the common values that serve as our compass. It defines principles that we can implement in daily life. It establishes binding guidelines where legal provisions dictate our actions.

The first letters of our corporate values spell the German word “prima”, meaning “great”. The letters stand for:
 

Performance,
Responsibility,
Integrity,
Mutability,
Appreciation.


Compliance

Observing our company's values (PRIMA), legal provisions and internal policies holds great significance at Aurubis, as illegal conduct can cause considerable damage and lead to offense proceedings or criminal proceedings. Furthermore, there is the danger of harming the company's reputation and thus its market position.
 

The term "compliance" refers to conduct that is consistent with specific requirements. These include laws, regulations and internal company policies, e.g. a code of conduct or ethics.
 

Since the Aurubis Group acts through its employees, every employee is obligated to follow applicable laws. Internal corporate conduct policies (e.g. Code of Conduct, Compliance Policy, Antitrust Law Policy, Anti-Corruption Policy) provide employees with standards for lawful conduct. The principles formulated in these policies apply in particular to interactions with customers, suppliers, other companies, shareholders, authorities, employees and supervisors and include adherence to anti-discrimination provisions, product and occupational safety regulations and environmental protection, in addition to prohibiting anti-competitive behavior and corruption.
 

Observance of legal provisions and conduct policies is ensured by three factors: prevention, monitoring and sanctions. Preventive measures include internal policies, consultation and especially employee training. For example, employees regularly participate in face-to-face and online training related to the topics of antitrust law and anti-corruption. Corporate auditing has a monitoring function. It verifies whether provisions and internal policies are being observed. If breaches of the law or internal policies are discovered, sanctions come into effect under labor law, civil law or even criminal law.

 

Aurubis has appointed a Chief Compliance Officer (CCO) in order to better fulfill the extensive requirements resulting from legal standards and conduct policies. The CCO is the central contact for all questions relevant to compliance and is responsible for further incorporating the issue of compliance into the company culture. He ensures that the same rules apply to all employees in the Group.
Local compliance officers at the individual Group sites are also available to answer employees’ questions.

Compliance Portal "Whistleblower - Hotline"

At Aurubis, tips can be submitted anonymously using an external and independent Compliance Portal. The Ombud Service Attorneys are available as a trustworthy reporting point. This reporting point (Aurubis Compliance Portal) can be contacted around the clock by phone, online form, e-mail or fax to report reasonable suspicion of conduct that could be relevant from a criminal law perspective or that could damage the company (e.g. corruption, fraud, violations of antitrust law).
 


OSR Investigativ© Compliance Portal

Phone: +49 (0)700 287 824 724
Fax: +49 7161 98 77 956
E-mail: aurubis(at)ombudservice.de

 

OMBUD SERVICE Rechtsanwälte
Eugenstrasse 18
D-73033 Göppingen