Code of Conduct ALPLA

This Code of Conduct applies to all employees worldwide who work at an ALPLA Group company or a company in which ALPLA holds a controlling interest. This Code of Conduct helps employees, executives and all business partners to understand the values and principles strengthening our company and thus serves as a basis for taking decisions and action. 

It is important that all employees have the opportunity to find out about the principles and behavioural rules that apply. Therefore, our Code of Conduct will be available in numerous languages. The English version of the Code of Conduct will serve as the benchmark.

Dealings with our business partners will also be governed by our Code of Conduct at all times. With this in mind, we expect our business partners to undertake to follow our ‘Supplier Code of Conduct’ if they do not have an equivalent code of conduct of their own.

The ALPLA Identity describes in short, simple statements why we as a company exist, who we are, how we act and what we do. It is our culture; it is what makes us unique. Each and every employee plays a crucial role in making sure with his/her actions and behaviour that the statements are not only written words but represent truly what defines us as a company. The ALPLA Identity consists of the following four parts:

OUR PURPOSE - Why we exist: Providing solutions for safe, affordable and sustainable living worldwide.

OUR PERSONALITY - Who we are: We value our people. We enable customer success. We are entrepreneurs. We care about the planet. We are one global family of pioneers.

OUR PROMISE - How we act: We create trust. We build on respect. We develop potential. We ensure excellent results.

OUR PRINCIPLES - What we do: Be reliable. Solve problems. Make decisions. Communicate effectively.

Our Code of Conduct conforms with internationally recognized ethical standards and the principles of the Ethical Trading Initiative Base Code, the International Labour Organisation (ILO), the United Nations Global Compact, the United Nations Guiding Principles and statutory legislation. We respect and support these values and principles, which we regard as the basis for our day-to-day decision-making and actions.

ALPLA, all ALPLA Group companies and employees as well as all business partners are required to obey the applicable laws.

Anti-Competition

ALPLA is committed to free and fair competition. We obey and follow antitrust and competition laws in all countries where we are operating. 

Anti-Corruption, Gifts and Hospitality

ALPLA is committed to free and fair competition. This commitment includes the rejection of any form of corruption. It is prohibited to offer, promise, grant, demand or accept financial or other advantages. It can, in individual cases, be difficult to distinguish between legitimate gifts and corrupt behaviour. For more details on how to behave when dealing with third parties, particularly customers, suppliers and official bodies, please refer to our Anti-Corruption Policy.

Conflicts of Interest

The actions of all ALPLA employees must be solely geared towards the success and interests of the company. All employees are therefore required to avoid situations in which their personal interests could come into conflict with those of the company. Conflicts of interest also occur in situations that do not relate to the direct personal interests of the employee, but rather to those of close relatives (e.g. husband, wife, partner, children, siblings, parents). Should conflicts of interest nonetheless arise, they must be disclosed immediately and in full to the line manager of the employee concerned. Potential conflicts of interest include:

• Work at/investments in other companies, especially competitors, that could constrain the employee’s ability to do their job at ALPLA
• Ownership of significant interests in companies that are business partners of ALPLA (this does not apply, of course, to private financial investments, such as share portfolios)
• Business dealings with companies or private individuals with ties to close relatives or similar ties (spouse, parents, children, people living in the same household)
• Secondary employment that may run contrary to the interests of ALPLA
• Donations and sponsorship
• The use of company facilities for private purposes (exceptions must be expressly approved by senior management)

Foreign Trade and Export Controls

Goods, suppliers, customers, countries and technologies are regulated by national and international customs, trade and export control regulations. In order to comply with these applicable regulations we maintain adequate controls and procedures. 
 

Respecting Human Rights
We are committed to obey and promote the human rights as affirmed by the Universal Declaration of Human Rights in the course of our work, including our supply- and value-chain. We comply with all relevant applicable labour laws and regulations.
Child Labour and Young Persons
We do not tolerate child labour under any circumstances and seek to completely prevent it.
We comply with the standards of the International Labour Organisation (ILO). 
Children under the age of 15 may not be employed unless they are doing so as part of an apprenticeship approved by government authorities. Children and young persons under 18 shall not be employed at night or shall execute hazardous work.
Freely chosen and formal employment
Our employees are in freely chosen employment. We do not accept any forced or involuntary labour of any kind. The work performed by our employees is carried out on the basis of a formal employment contract, which, in turn, is based on national employment law in the country concerned.
Fair terms of Employment
All workers are provided with simple, written contracts which must detail the terms and conditions of their employment. Work carried out must be in line with the applicable local employment law and our Code of Conduct.
Fair compensation
Wages and benefits should meet national standards or collective labour agreements, where applicable, aiming at providing a sustainable living wage, determined in partnership with all relevant stakeholders. Workers should be provided with clear written information on their pay and working conditions. All use of temporary and/or outsourced labour shall be within the limits of the local law. In case we are using any third-party employment agencies we are to ensure that these are compliant with the provisions of this Code of Conduct and the law.
Freedom of assembly and the right to collective bargaining
All employees have the right to establish and join a trade union, as well as conduct collective bargaining negotiations.
Working time
Our working times comply with international standards and do not exceed the limits imposed by the national laws or collective agreements of the country concerned.
No discrimination
All forms of discrimination are prohibited, both within ALPLA and in dealings with third parties. Our company is enriched by diversity. Decisions taken in respect of employees or applicants must not be based on race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, union membership or political affiliation.
No harassment
Sexual harassment, physical or verbal abuse, any form of intimidation, bullying and other types of disrespectful behaviour will not be tolerated at ALPLA. ALPLA provides access to a confidential grievance mechanism for all employees to report any type of harassment.
Land Rights
We protect and foster the land rights of local populations and indigenous peoples. We respect the ownership rights and deeds of individual indigenous people and local residents. All negotiations in respect of their property and land, as well as its use and transfer, are conducted in accordance with the principle of contractual transparency and disclosure, with voluntary and information-based prior consent.
We are operating legally in premises with the correct business licenses and permissions.
Migrant workers
All employees at ALPLA meet the legal criteria for working in the country concerned. All statutory requirements must be observed in the country in question. We expect the same from our business partners.
Safe and hygienic working conditions
Safe, hygienic working conditions and strict observance of occupational safety regulations are the cornerstones of our working organisation. Our employees must be given maximum protection. Therefore, the consumption of alcohol or drugs is not permitted during working hours.

ALPLA requires all employees to treat the company’s intellectual and physical property/information with the utmost care. By ‘information’ or ‘intellectual property’, we understand all financial data, technical data, research, contracts and correspondence within the ALPLA Group, irrespective of the method of storage, editing or transmission used.

All records and reports must be accurate and truthful and must be stored in accordance with applicable legislation. As the aforementioned documents generally relate to internal matters, confidentiality must be observed. This continues to apply after employment has ended and also covers employee, supplier and customer data. Personal data may only be stored and processed if it is necessary to do so for the performance of duties at the company. Confidential information may not be disclosed to third parties.
 

In particular, the IT regulations pertaining to software, hardware, email and the Internet must be observed. Each individual user has a duty of care in respect of any devices or data entrusted to them. Passwords or access codes must be kept secret and may not be disclosed or compromised.

All business data generated and administered on ALPLA IT systems must be stored on a server-based system so that this data can be backed up and, if necessary, restored.
 

This Code of Conduct is displayed in all HR departments, where it can also be viewed/requested in the relevant national language. When joining the company, new employees will be familiarised with our values and principles and will be asked to confirm that they have read and understood the Code of Conduct. The digital version of the Code of Conduct, along with translations into a range of languages, is available on our homepage and in Sharepoint, our in-house information system.
If any employee is unsure about how to apply these rules, if he/she witness any non-compliance or if they have any grievances, he/she can contact their line manager or the Compliance Officer at Corporate Headquarters in Hard (Austria):
ALPLA Werke Alwin Lehner GmbH & Co KG
Compliance Officer
Mockenstrasse 34
6971 Hard
Austria
Phone: +43 5574 602 163

or report the case anonymously via the Reporting Channel provided by an independent external provider. The Reporting Channel is accessible via ALPLA Pioneers 

Hub and ALPLA home page.
The Compliance Officer undertakes to treat all enquiries in a professional and confidential manner. Any potential and suspected breaches of the Code of Conduct will be taken seriously when reported and, on request, will be treated confidentially and on an anonymous basis. The facts of the case will be investigated impartially and with due care. If breaches are identified, the necessary corrective and/or disciplinary measures will be initiated.

Where there is doubt as to whether a situation or action constitutes a breach or not, it may help to ask the following questions:
-    Is it legal?
-    Is it ethical?
-    Does it comply with the ALPLA principles?
-    Does it strengthen the good reputation of the company?

If the answer to any one of these questions is ‘no’, we advise against the action concerned. If you are still unsure, the Compliance Officer will be happy to answer your questions. Furthermore, compliance with the values and principles outlined is verified globally in the form of internal and external audits carried out by impartial third parties and documented in the corresponding audit reports. In this way, we ensure that all regulations and provisions are observed at the individual companies of the ALPLA Group.

By the same token, it is in the interests of the company to not only look inwards in terms of its focus on ethical and sustainable dealings with people and natural resources. Therefore, we also expect our business partners to observe the values and principles outlined.