MSD 8.47.3.16
Fraport Twin Star Airport Management AD
Value Management
Standards of Behavior
Fraport Twin Star
Airport Management AD
Revision: 3.0
Valid from: 26.01.2012
Author: HR, EDD
Publisher: IMS & IA, VPN
0Underlined: Modification
-/-/-/-: Clearenced
Page.: 1/8
MSD 8.47.3.16
Contents
1. Foreword
2. Basic Values
•
Honesty
•
Integrity
•
Trustworthiness
•
Responsibility
•
Transparency
•
Loyalty
•
Fairness
•
Sustainability
•
Quality
•
Teamwork
•
Innovation
3. Standards of Behavior
3.1 Obligation of employees to abide by the law
3.2 Dealing with gifts and benefits
3.3 Loyalty towards the company’s interests
Fraport Twin Star
Airport Management AD
Revision: 3.0
Valid from: 26.01.2012
Author: HR, EDD
Publisher: IMS & IA, VPN
0Underlined: Modification
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Page.: 2/8
MSD 8.47.3.16
1. Foreword
In 2003, Fraport AG introduced a Values Management System. It is part of the program to
systematically extend the values orientation within all subsidiaries in Fraport Group. In
relation to this we- Fraport Twin Star Airport Management AD accept to follow the basic
values and standards of behavior of the Group promoting ethical conduct by the employees
and business partners and sanctioning the cases of violation.
In recent years, numerous scandals have severely damaged the reputation of the
companies involved. The consequences of illegal and unethical practices are also
considerable in economic terms; they can harm a company’s competitiveness and
endanger jobs.
The introduction of a values management system in Fraport Twin Star Airport Management
AD was prompted by the awareness that illegal and unethical practices can neither be
prevented by laws nor tight internal controls alone. We additionally require clearly agreed
ethical standards that are systematically applied and filled with life. The basic values of
honesty, integrity, trustworthiness, responsibility, transparency, loyalty, fairness,
sustainability, quality, teamwork and innovation are expected from us as well as from our
business partners. These basic values are binding for all employees and at all levels of our
company. We do our best to ensure that the Standards of Behavior derived from them are
the basis for cooperating in a spirit of partnership.
The Values Management System takes concrete form in our Standards of Behavior.
Specifically, these standards cover the obligation of employees to abide by the law, the
dealing with gifts and benefits, and the loyalty towards the company’s interests. These
rules illustrate and facilitate practicing our basic values on an everyday level and give our
employees a clear orientation.
The values management system does not function by itself, nor can it be introduced simply
by pressing a button. It is, rather, a living process. It can only succeed if the defined basic
ethical values are truly applied in everyday company life. In order for values management
to develop and grow, all managers in particular must make a major commitment to it. It is
essential to pay greater attention and increase awareness of our organization’s ethical
values. So please support this process and work with the Management to strengthen our
company’s ethical standing.
Fraport Twin Star
Airport Management AD
Revision: 3.0
Valid from: 26.01.2012
Author: HR, EDD
Publisher: IMS & IA, VPN
0Underlined: Modification
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Page.: 3/8
MSD 8.47.3.16
2. Basic Values
Honesty
We refrain from everything that could hurt our good reputation, and we behave like
honorable businesspeople. In all of our business activities, we comply with the relevant
laws and regulations.
Integrity
We let all of our company’s communications and activities be guided by our values.
Trustworthiness
We make no promises we cannot keep, and our word is our obligation.
Responsibility
We know that our business activities must be consistent with the interests of society and
are prepared to accept the consequences of our actions.
Transparency
We openly provide information on important decisions and developments in the company,
thus establishing a basis for cooperation in an atmosphere of trust. Failures to abide by
laws and in-company regulations are investigated and dealt with.
Loyalty
We attach great value to respecting each and every employee. Correspondingly, we expect
our employees to identify with the company’s goals and to be loyal to its interests.
Fairness
We regard proper, fair conduct in compliance with the “rules of the game”, in dealings both
with one another and with business partners, as essential for our success.
Sustainability
As an employer and company, we are aware of the responsibility we have toward our
employees, society and the environment. We conduct our activities in keeping with the
principles of sustainability and base our business activities on economic, environmental
and social criteria.
Quality
We provide high-quality services that are geared to our customers’ needs.
Teamwork
We contribute and encourage the teamwork. Each of us carries unique culture and talent.
Together as a team we can win by sharing our experience and successes. Communicating,
helping and training each other we increase our effectiveness and results.
Innovation
We share our ideas for better development of our company. The innovations are the power
of the progress. Each idea for improving the organization, processes, culture and the
products is valuable and important for the company and our professional development.
Fraport Twin Star
Airport Management AD
Revision: 3.0
Valid from: 26.01.2012
Author: HR, EDD
Publisher: IMS & IA, VPN
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MSD 8.47.3.16
3. Standards of
Behavior
The Standards of Behavior of the Fraport Twin Star reflect our basic values and establish
binding rules for dealing with the ethical, commercial, and legal challenges of everyday
business.
Standards of Behavior cannot and should not provide detailed instructions on how to act in
every possible situation. Where necessary, their application is defined by specific
guidelines and rules. Questions on how to interpret the standards in concrete situations
should be addressed, and possible violations reported, to the responsible manager. The
Fraport Twin Star’s Hotline of the Ombudsman is also available for confidential
consultations on these matters.
3.1 Obligation of employees
to abide by the law
In all of our business concerns, we expect that relevant laws and regulations are respected
and complied with. Our worldwide activities conform to the legal requirements applicable in
each case. We cannot and will not accept any conduct that could call into question or
jeopardize our integrity. Employees and managers violating this requirement must, should
expect disciplinary action on our part.
Within this context, we adhere to the following principles for acquiring orders, etc.:
a)
It is the philosophy of our company that orders should be won through fair
competition. We rely on innovative quality and price advantages, and we reject
price and quantity-fixing agreements as well as bids rigged with competitors. Our
activities are governed by the guidelines of national and international legislation.
b)
We refrain from attempting to win orders by granting or offering direct or indirect,
unjustified or illegal advantages to others.
c)
We do not offer public servants or other official gifts or other benefits in connection
with the placing of orders or the fulfillment of their official duties. We reject all forms
of corruption. The relevant laws must strictly be observed.
3.2 Dealing with Gifts
and Benefits
Our approach to gifts, invitations, and other benefits is characterized by the principles of
legality, responsibility, and appropriateness. As a general rule for judging the
appropriateness of a gift or benefit, it must neither be necessary for the recipient to conceal
acceptance of it, nor should it impose any kind of obligation. There must be no objections
whatsoever to superiors and coworkers knowing of it. We accept no gray areas instead we
fully disclose all actions by documenting them and practicing transparency. Under no
circumstance is bribery acceptable.
Any violation of these obligations will be responded to with disciplinary action, which can
extend as far as terminating an employee’s contract. Employees can also be held
accountable for damages and losses resulting from improper conduct.
We expect our suppliers to take active measures to prevent corruption in their company.
We see this as positive, because it is essential for achieving long term business
relationships with mutual benefits:
Fraport Twin Star
Airport Management AD
Revision: 3.0
Valid from: 26.01.2012
Author: HR, EDD
Publisher: IMS & IA, VPN
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MSD 8.47.3.16
3.2.1 Accepting Gifts and Benefits
Our company’s employees are strictly forbidden to accept the following types of gifts or
benefits in connection, either directly or indirectly, with awarding and handling contracts or
other business dealings between our company and our business partners:
a) Money: e.g., cash, remittances, transfers by third parties to accounts of Fraport Twin
Star’s employees or members of their families, interest-free or low-interest loans, or
remuneration for private secondary employment that exceeds what is appropriate for
the services rendered.
b) Material assets and monetary equivalents: e.g., alcoholic beverages, clothing,
jewelry, admission tickets and vouchers, if the value of the gifts exceeds 30 EUR; air
travel tickets, use of objects or vehicles free of charge or at reduced rates, invitations
to go on holiday trips, and offers to make purchases at discount prices, unless such
offers are made to the entire workforce of Fraport Twin Star. Multiple submissions of
material acquisitions at a similar amount should be avoided.
In keeping with the principle of appropriateness, we accept customary gifts that have only
little material value or symbolic value not exceeding the defined upper limit 30 EUR. This
also applies to business meals, meals and refreshments provided in connection with
inaugurations, topping-out ceremonies and social events or other work-related occasions.
The aspect of appropriateness applies at all hierarchical levels and must be appropriately
applied in each case. A good rule of thumb is that the recipient should not need to keep the
acceptance of a gift secret and should not be obligated in any way by it. Moreover, we
should not have any objections whatsoever to our superiors and coworkers learning of it. In
case of doubt, the employee’s superior must be notified to obtain his or her permission.
Approved exceptions to the general prohibition of accepting gifts and benefits must be
documented.
3.2.2 Giving of Gifts and Benefits
We define gifts and benefits given to customers as everything they receive in connection
with a business relationship without paying an appropriate market price. The giving of gifts
and benefits is not acceptable if they can be regarded as attempts to illegally or unfairly
influence objective decisions by customers and create obligations and dependencies.
To illustrate this, it is not acceptable to provide any of the following gifts and benefits to
customers:
a) Money: e.g., cash, remittances, transfers by third parties to accounts of customers,
interest-free or low-interest loans, or remuneration for private secondary employment
that exceeds what is appropriate for the services rendered. It is an exception sums
to be transferred in cases, when the Management Board has taken a decision
certain amounts to be granted, after this has been suggested by the Social
Committee.
b) Material assets and monetary equivalents: e.g., alcoholic beverages, clothing,
jewelry, admission tickets and vouchers if the value of the gifts exceeds 30 EUR; air
travel tickets, use of objects or vehicles free of charge or at reduced rates, holiday
trips, or disproportionately high remuneration for services rendered.
In keeping with the principle of appropriateness, we therefore restrict ourselves from giving
gifts and articles that:
• exceed the amount of 30 EUR,
• bear the logo of Fraport Twin Star, and
• are related to an event sponsored by Fraport Twin Star.
Fraport Twin Star
Airport Management AD
Revision: 3.0
Valid from: 26.01.2012
Author: HR, EDD
Publisher: IMS & IA, VPN
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MSD 8.47.3.16
To ensure adequate transparency, all exceptions and deviations from these rules must be
documented and approved by the responsible superior. This applies at all levels of the
company’s hierarchy.
In this context, we expressly refer to the legal provisions on corruption as set forth in
Criminal Code.
3.3 Loyalty towards the
Company’s Interests
We attach great value to respecting each and every employee. Promoting and developing
employee potentials is a core task of managerial responsibility. Correspondingly, we expect
our employees to identify with the company’s goals and to be loyal to its interests. A
conflict of interests arises if an employee’s personal interests could interfere with or impair
the company’s interests. Employees are therefore expected to avoid situations that could
lead to a conflict of loyalties.
To prevent such conflicts, all employees of Fraport Twin Star must observe the following
rules:
a)
Employees involved in awarding contracts and making purchases must make it
known if family members or friends of theirs have a substantial financial stake or
interest in a supplier. Employees must inform their superiors of possible conflicts of
interest immediately and submit a written report.
b)
No employee may own a significant stake in a company that competes with Fraport
Twin Star or one of its affiliated companies, unless Fraport Twin Star has given its
prior consent. The holding of a significant stake in a company that has substantial
business dealings with Fraport Twin Star or one of its affiliated companies — either
directly or indirectly — must be reported in writing, specifying the nature and extent
of the employee’s involvement. It is accepted that a person possesses a significant
share in a company and controls independently more than the half of the votes in
the General Assembly in a company according to a deal with another associates or
shareholders in the same company.
c)
The employeеs may accept secondary employment with other employers for
working out the settled work schedule to the basic labour agreement, unless
another condition has been agreed in the personal labour contract.
Honorary public offices held on a voluntary basis, i.e., without remuneration, are
not regarded as secondary employment, but as civil involvement, which we
encourage.
d)
It is forbidden to make company information available to third parties. Employees
must treat the company’s internal affairs confidentially vis-à-vis all parties within
and outside the company.
“Internal information” is the concrete information, which is not published or officially
announced by the company and refers directly or not directly to Fraport Twin Star Airport
Management AD: information in some form (no matter what kind of form) which, when
there is a question of written or oral information, and at the moment of revealing it, it is
pointed out as confidential/ internal information, and its announcement could harm or have
negative effect on the interests of the company, related with the security, financial status,
internal company policy, established procedures, or could harm another’s legal interest.
We accept that internal information is the information submitted by a partner- company,
organization or institution, according to an agreement, in which Fraport Twin Star Airtport
Management AD is a party. Internal information is the information, connected with carrying
out of procedures according to the Public Procurement Act, which has been learned about
by the employees as a result of their obligations’ compliance. It is not admissible to reveal
accounting or financial information, except for the information stipulated in the Law on
Accountancy and International Accountancy Norms, which is officially announced.
Fraport Twin Star
Airport Management AD
Revision: 3.0
Valid from: 26.01.2012
Author: HR, EDD
Publisher: IMS & IA, VPN
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MSD 8.47.3.16
The following reports and facts are internal information
• Information about the systems and security organization of the company;
• Information regarding negotiations, the contents of concluded contracts with
parties, their character and provisions;
• Lawsuits, correspondence with the prosecutor’s office and the judicial inquiry,
when they include confidential information which is an official secret;
• The nominal pay-roll list, personal data of the employees and their personal
labour files;
• The amount of the labour remuneration;
• Documents of other organizations and firms, which have been received in the
company, and which have been appointed by them as an official secret;
• Summarized information about the buildings and projects of the companysketches, architectural or construction plans, sketch of the computer net;
• All information, whose revealing and announcement could harm the company’s
prestige and cause property damage or future earnings.
It is admissible the announcement and revealing of the following information:
• General information for the company, its history and the establishment;
• Information about the shareholders’ structure;
• Information about the Management body;
• Information about forthcoming events;
• Important representative information and materials, related with the company’s
activity and with advertising purposes.
The violation of some of the above-mentioned rules is a violation of the work discipline.
Disciplinary punishment, stipulated in the Labour Code will be imposed to the guilty
persons.
e) Company property, and especially equipment and installations in offices and
workshops, may only be used for work-related purposes. Exceptions to this rule
and payment for the personal use of equipment and installations must be approved
and documented by the responsible superior.
f)
Fraport Twin Star
Airport Management AD
We accept as unmoral and unethical all cases when the objectivity of the decisions
for employment, promotions, sanctions or assessment of the work is impaired, thus
we shall not tolerated the employees or applicants with relative, friendship or there
kind of relationship with the management.
Revision: 3.0
Valid from: 26.01.2012
Author: HR, EDD
Publisher: IMS & IA, VPN
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