Gänsäcker 15, D-78532 Tuttlingen
General Guiding Principles for all personnel working with and for Medicon, companies, institutions, offices, authorities and medical facilities.
– hereinafter referred to as employees and business partners.
The following guidelines of conduct apply to Medicon’s interaction with employees and business partners as well as to the interaction of Medicon’s business partners with third parties (employees, companies, institutions, authorities and medical facilities).
Fair competition and fair practices
Medicon eG and its business partners compete for all business opportunities in a fair and ethical manner. All national and international antitrust laws and fair competition laws shall be fully complied with in the respective country of application.
The employees of Medicon eG and its business partners must not participate in covert tendering, price fixing, price discrimination or other unfair and/or dishonest trade practices.
Marketing and distribution
Medicon eG and its business partners ensure that accurate communication of their products and services is disseminated. All regulatory and legal requirements applicable to the marketing and sale of Medicon products and services shall be complied with.
Fair interaction with employees and business partners
Medicon eG and its business partners maintain and promote fair interaction with employees and business partners to not engage to take advantage of anyone through manipulation, concealment or misuse of privileged information, misrepresentation of material facts or other unfair acts or practices.
The focus is on the customer
Medicon eG and its business partners build solid customer relationships characterized by mutual trust and provide each customer with the most sensible solution for each particular situation and/or circumstance, enquiry and need.
Cooperation among employees
Medicon’s eG management and its business partners provide a positive working environment where all employees and business partners can develop. Working within this framework allows all employees and business partners of Medicon eG to flourish and prosper.
The work and success of Medicon eG and its business partners is based on trust and reliability. This leads to mutually durable and long-lasting customer relationships.
Medicon eG and its business partners communicate honestly and openly – in all situations that business life can bring.
Medicon eG and its business partners are familiar with the constant changes in the business world. Part of their success is their ability to change in order to always meet the demands of the times with appropriate products and solutions.
Medicon eG and its business partners comply with all applicable local, national and international statutes, laws, ordinances, rules, codes, standards, guidelines and regulations of the jurisdictions in which business relationships are maintained.
The most stringent requirements apply in each case when multiple laws and regulations are potentially applicable to the issues.
Compliance with trade and customs laws
Medicon eG and its business partners comply with all applicable trade and customs laws of the countries in which they operate.
Proper accounting and records
Medicon eG and its business partners are responsible for ensuring that all assets, liabilities, revenues, expenses and transactions are properly and accurately recorded in the accounting records and documents of the relevant entity. These records are kept in accordance with relevant legislation, accepted accounting principles and the company’s financial policies/procedures.
Antitrust / Competition Law
Medicon eG and its business partners operate in accordance with the applicable competition laws in their respective markets. Abuse of a dominant market position, price-influencing agreements or collusion among business partners will not be tolerated in accordance with antitrust law.
Medicon eG and its business partners develop and establish methods and processes for Medicon products that reduce the risk of using counterfeit components and materials.
Corporate integrity / Anti-corruption
Medicon eG and its business partners expressly refrain from any form of corruption, extortion and/or embezzlement. International and national regulations against corruption must not be violated.
Bribes – in whatever form – may not be offered, accepted or tolerated by any of the above-mentioned parties in order to gain an unfair business advantage.
Invitations / Gifts
Medicon eG and its business partners are prohibited from offering, promising or granting personal benefits to business partners if the aim is to influence procurement decisions. Likewise, personal benefits may not be demanded or accepted from employees and managers of Medicon eG if this could be intended to exert an undue influence.
Preventing conflicts of interest
Medicon eG and its business partners are expected to make their decisions only according to objective standards. All factors that may influence the opinion of a business partner due to private, business or other conflicts of interest are to be disclosed – or even better – avoided from the very beginning.
Conduct and support events for healthcare professionals
For healthcare professionals, the cost of attending educational events as delegates or lecturers may be funded, provided this is done in accordance with local professional codes, laws and regulations.
Medicon eG and its business partners do not make improper payments to government or non-government officials, employees, customers, individuals or legal entities and do not request or accept improper payments from suppliers, customers or other persons who wish to do business with them.
Medicon eG and its business partners will not, directly or indirectly, offer, promise, provide, solicit or accept bribes or kickbacks of any kind, either in interaction with public or government officials (including health care professionals and employees) or with other entities or individuals in the private sector.
Medicon eG and its business partners must comply with the anti-corruption and anti-money laundering laws of the countries in which they do business and all other applicable prohibitions on any bribery, improper rebates or other corrupt practices and any successor or replacement statutes, laws and regulations, including, but not limited to, and as far as applicable, the United States Foreign Corrupt Practices Act and the United Kingdom Bribery Act of 2010.
Medicon eG and its business partners are prohibited from using child labor. The minimum age for employment relationships must be observed in accordance with international requirements (cf. ILO). All applicable child labor laws must be complied with.
Forced labor, involuntary labor and human trafficking
Medicon eG and its business partners do not support, promote or use forced labor, slavery, involuntary labor or human trafficking of any kind.
Immigration laws and proper documentation
Medicon eG and its business partners may only employ or engage employees who have the right to work in the country in which Medicon or its business partners intend to hire these employees.
Medicon eG and its business partners verify appropriate and relevant documentation and the legal status of potential employees before hiring them.
Prohibition of discrimination
Medicon eG and its business partners ensure that human dignity and respect are protected.
They shall not discriminate or support or tolerate discrimination in the workplace or in any business transaction on the basis of race, colour, sex, age, religion, marital status, caste, social origin, disability, pregnancy, ethnic or national origin, military service, nationality, sexuality, gender identity or any other personal characteristic or status protected by applicable laws.
Prohibition of intimidation, harassment or abuse
Medicon eG and its business partners shall refrain from and prevent the intimidation, harassment or abuse of any person.
Wage and salary payments
Medicon eG and its business partners calculate salaries and wages at minimum on the basis of the corresponding applicable laws and pay them on time.
All applicable wage and labor time laws and regulations shall be complied with,
including those related to minimum wages, overtime, piece rates and proper classification.
Prohibition of salary deductions
Medicon eG and its business partners do not make unauthorized, legally unsupported salary deductions. Gehaltsabzüge als Disziplinarmaßnahme zu missbrauchen, ist unzulässig. Using salary deductions as a disciplinary measure is not permitted.
Equal treatment of all employees
Medicon eG and its business partners assure that all employees are treated equally with regard to all conditions associated with the employment. These include:
– Terms of contract
– Access to education and training
– Career planning
Medicon eG and its business partners ensure that working hours comply with national laws or industry standards. If there is a conflict between the two, the regulation that benefits the employee the most is chosen.
The maximum working hours permitted by law must not be exceeded. It must be ensured that overtime is paid or compensated in accordance with local laws and regulations.
Freedom of association
Medicon eG and its business partners comply with all laws that allow employees the right to freedom of association in a legally constituted group (e.g. a trade union or labor organizations).
Medicon eG and its business partners ensure a safe and healthy working environment and comply with all applicable health and safety laws, including, where applicable, those relating to accidents and diseases at work, emergency preparedness and work safety.
Prevention of accidents, injuries and hazards
It is the goal of Medicon eG and its business partners to maintain a safe and healthy environment for all employees and to prevent or minimize the risk of work related accidents and damage to health as far as possible.
Medicon and its business partners shall at all times ensure adequate security at its facilities. We expect employees of business partners to comply with security procedures when they are visiting facilities of Medicon eG.
Medicon eG and its business partners respect the proprietary rights of third parties to intellectual property: patents, trademarks and copyrights. They comply with the requirements and conditions for their use.
Medicon eG and its business partners shall not disclose any confidential and proprietary information of third parties (trade secrets, knowledge, designs, data, skills or other confidential and proprietary information) without their express written consent.
Medicon eG and its business partners treat all personal data confidential and in compliance with all data protection laws applicable to such personal data.
To this end, Medicon eG and its business partners take appropriate technical and organizational measures to secure personal data, protect information and prevent unauthorized access, alteration or loss of such data.
Security and use of information systems
Medicon eG and its business partners follow appropriate procedures for the security and confidentiality
– of passwords
– in the provision of products or services
– access to internal systems, networks and facilities
The technology provided may only be used for approved, business-related purposes.
Employees of Medicon eG and its business partners must not knowingly download, view or send any material or hazardous content of a discriminatory, harassing, threatening, sexual, pornographic, racist, sexist, defamatory or otherwise offensive nature.
Medicon eG and its business partners comply company-wide with all applicable laws, regulations, standards, ordinances, rules, permits, approvals and orders relating to the environment and the use of substances.
All required environmental permissions, licenses, registrations and approvals must be followed, as well as any operational reporting requirements demanded by the laws, regulations, standards, ordinances, etc. of the country in which the facility is located.
These requirements apply to, but are not limited to, procurement, production, distribution, disposal, energy consumption and emissions within the business processes of Medicon eG and its business partners.
Waste management, disposal of chemicals
Medicon eG and its business partners comply with all applicable environmental laws and regulations relating to waste, hazardous or toxic substances, chemicals in products that are required by governments and other agencies in the
countries/regions where they are used are regulated.
The procedures for
– Waste management
– Handling & disposal of chemicals and other hazardous substances
– Wastewater treatment
must comply with the applicable guidelines.
In addition, all environmental permits required under local law must be obtained and updated on a regular basis.
Medicon eG and its business partners give preference to environmentally friendly technologies and develop measures for recycling or reusing materials.
Medicon eG and its business partners take measures to determine whether their products contain conflict minerals (tin, tantalum, gold and tungsten).
If this is the case, they establish due diligence processes in the supply chain to identify the sources of these minerals and support efforts to prevent the use of conflict minerals that directly or indirectly fund or benefit armed groups in countries identified in conflict minerals laws or regulations.
Medicon eG and its business partners encourage employees to record all information on business processes accurately and honestly.
No employee will sign or submit any document or statement that is believed to be false.
All records and reports shall be prepared, stored and destroyed in accordance with applicable legal and regulatory requirements.
Medicon and its business partners encourage employees to seek advice from the Medicon management and their representatives (authorized signatories) or the management or responsible contact persons in the event of uncertainty, ambiguity or doubt regarding the application of these guidelines.
Medicon and its business partners encourage employees to refer violations of these guidelines to the appropriate confidential personnel within the company. This way, there is protection for any employee who in good faith reports violations of the guidelines or investigates such a process. Medicon and its business partners will not tolerate any form of retaliation or other penalties on any employee who in good faith reports a violation of the guidelines or cooperates in the investigation of such a report.
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