Version 3.0
Effective Date: June 2024
Regulatory Compliance
Legal regulations apply to everyone, requiring honest and complete adherence to both legal man-dates and ethical standards. By following the rules and principles outlined in our Code of Conduct, we actively establish the fundamental guidelines of our behavior. This ensures that we fulfill our spe-cific responsibilities as a globally operating company and lay the foundation for a successful and sus-tainable future. Any violations of these regulations or the Code of Conduct are subject to sanctions and may lead to criminal consequences.
As employees, we conduct ourselves with integrity and in alignment with all relevant laws. To achieve this, PALFINGER has implemented measures and processes, e.g. targeted training, to ensure com-pliance with all applicable legal requirements.
Standards of the Code
HUMAN RIGHTS & WORKING CONDITIONS
Our products and services are based on the commitment of many people. Our success depends on healthy and fairly treated employees. Therefore, we protect their rights and follow the principles of the United Nations Global Compact initiative and the International Labor Organization.
"Behind all the milestones we’ve reached, are the people who give their best every day. Their health and safety always has top priority." Andreas Klauser, CEO
a. Prohibition of slavery and human trafficking
Human trafficking or slavery are illegal. We will promptly follow up on any notice of such practices and ensure that they are stopped immediately. We make sure that employees and business partners do not directly or indirectly promote or support these crimes.
b. Prohibition of child labour
Child labour is strictly prohibited. We adhere to the conventions of the International Labour Organiza-tion on the minimum age for employment. This age limit guarantees children and adolescents their full physical and mental development.
c. Free choice of employment
Forced or compulsory labour is illegal. Employees at PALFINGER can terminate their employment relationship at any time with reasonable notice. We do not take identity cards, passports or work per-mits as a condition for employment.
d. Protection against discrimination / harassment / bullying
We view diversity as a source of strength. As such, we do not tolerate any form of discrimination, harassment or bullying related to ethnic or social origin, nationality, skin colour, gender, sexual orien-tation, age, religion, political beliefs, affiliation with legal entities or other personal characteristics. We are dedicated to providing equal opportunities and fair treatment to all individuals. Everyone is entitled to a workplace environment that is secure and respectful.
e. Prohibition of weapons, alcohol and drugs
We handle conflicts through peaceful and non-violent means. Weapons are strictly forbidden in the workplace.
Additionally, the use of alcohol and drugs at work is prohibited, except in cases of medical necessity.
f. Freedom of association
We encourage open communication between employees and management regarding working condi-tions, free from any fear of reprisal. Every employee has the right to join or establish trade unions or other associations. This includes the freedom to engage in collective bargaining.
g. Health and safety
Ensuring health and safety is one of our foremost concern. We actively foster healthy and safe work environments, and collaborate to consistently improve them. Our employees receive training and are encouraged to report unsafe conditions without fear of disadvantage. We provide all employees with access to occupational health care services. Management is responsible for the health and safety of employees in their area of responsibility.
In cases where national regulations fall short of ensuring sufficiently health and safety standards, PALFINGER implements supplementary occupational health and safety measures, including volun-tary health initiatives.
h. Compliance with working hours and minimum wage
We ensure fair working conditions, comply with working time regulations and safeguard that the statu-tory minimum wage is not undercut. This includes the fair compensation of overtime as well as adhering to the law regarding breaks and vacation time.
"Diversity at PALFINGER is not only a strength, but also a source of innovation and creativity. Different perspectives and backgrounds enrich our corporate culture and contribute to our success." Maria Koller, CHRO
BUSINESS ETHICS
We consider social responsibility and sustainability in our decision-making process. This includes con-sidering not only economic factors but also the social and ethical implications of our choices. We ac-tively contribute to our community and strive to generate long-term value.
a. Anti-Corruption
We do not tolerate any form of corruption. Any kind of hidden commissions or other illicit payments in return for facilitating a transaction is also strictly prohibited at PALFINGER.
PALFINGER employees are only allowed to offer or accept gifts of low value. Any gifts in the form of money, vouchers or gifts that violate laws or moral values are prohibited in any case. We do not accept any form of bribery in which employees offer or accept gifts in order to achieve an improper act.
b. Economic crime
At PALFINGER, we focus on integrity and transparency. Fraud and deliberate misrepresentation con-tradict our values and are strictly prohibited. This includes the manipulation of information as well as the misuse of positions and resources.
c. Conflict of interest
Any potential conflicts of interest must be promptly disclosed. This includes, e.g. personal relationships with applicants or business partners. Prioritizing personal interests over those of the company is strictly prohibited. We avoid situations that can lead to such conflicts.
d. Ban on advertising for political parties
We uphold political neutrality and maintain a professional work environment. Advertising for political parties in any form is strictly prohibited within PALFINGER, whether it be through print media, broad-casting, social media, or any other channels.
e. Sponsorship and donations
Our sponsorship and donation activities are carefully selected. They are transparent, non-political and must not contradict our ethical standards.
f. Anti-Money Laundering and Terrorist Financing
We prevent any form of money laundering or terrorist financing. Any actions that directly or indirectly contribute to such violations are strictly prohibited.
g. Privacy
We prioritize the protection of personal data. We handle this information confidentially and adhere to relevant data protection laws. Our security measures safeguard against unauthorized access, misuse, or loss of personal data.
h. Artificial intelligence
We use artificial intelligence responsibly to drive positive social change. Our emphasis lies on a human-centered approach and equitable management of intellectual property and technological rights. Any misuse of artificial intelligence is strictly prohibited.
i. Protection of confidential information
We protect our trade secrets and information. Technical development and the corresponding know-how are of our utmost importance. Their unauthorized disclosure or use is prohibited. All specified measures for the protection of trade secrets and other business information must be strictly adhered to.
j. Protection of intellectual property
Intellectual property holds immense value for us. We respect and protect copyrights, trademarks, pa-tents and prevent their unlawful use or disclosure. This commitment extents to preventing plagiarism or the theft of intellectual property rights.
k. Antitrust and Competition Law
We act transparently and fairly in competition. Collusions or agreements that restrict competition and the exchange of information relevant to competition are prohibited.
l. Product Compliance
We are committed to ensuring that our products meet high quality and safety standards, in compliance with both national and international regulations. We attach great importance to comply with all relevant regulations, standards and certifications in development, production and distribution of our products.
m. Export Law & Sanctions
As a globally operating company, PALFINGER is subject to different export regulations and must com-ply with applicable sanction regulations. We consider these regulations in all our business activities and ensure transparency regarding our business partners.
n. Protection of company property
We take care of our company resources and protect them from any form of damage. This includes preventing destruction, misuse, theft, or unauthorized access.
o. Capital Labelled Compliance
As a listed company, we strictly adhere to capital market rules. Any form of market abuse, such as misuse of insider information, insider trading or market manipulation is prohibited.
"Economic success is important - but not at any price. Our commitment to legally and ethically compli-ant conduct guides and accompanies us on our way into the future." Felix Strohbichler, CFO
ENVIRONMENTAL STANDARDS
We are committed to resource-saving production and full compliance with all standards. Beyond meet-ing legal requirements, we continually seek environmentally friendly alternatives in production, supply chain management, and product development.
a. Environmental responsibility
We are committed to the environmental principles and goals of the UN Global Compact initiative for the benefit of all people. Therefore, we pursue a preventive approach, promote initiatives to minimise environmental impact and embrace green technologies.
b. Sustainable production
We focus on material and energy efficiency as well as the reduction of the CO2 footprint in all produc-tion phases. Our approach aims to prevent environmental risks and minimize emergencies.
c. Sustainable products
Sustainable products are one of our main goals. We are dedicated to making our products more envi-ronmentally friendly from start to finish, whether it is in research and development, or in how they are used and recycled. We prioritize sustainable materials and processes every step of the way.
"At PALFINGER, we place great emphasis on sustainability because we believe it's our duty to act responsibly for both current and future generations." Alexander Susanek, COO
Reporting misconduct
Reporting violations of our Code of Conduct is crucial for maintaining a positive and respectful work-place environment. We encourage all employees to bring any misconduct to the attention of their re-spective manager. Additionally, they can reach out to the HR department. Alternatively, misconduct can also be reported safely, confidentially, and without fear of retaliation through our whistleblower
system, known as the Integrity Line. Reports can be submitted anonymously or non-anonymously via the company website at https://www.palfinger.ag/en/integrity-line.
Scope
This Code of Conduct applies to all divisions, branches and companies that belong to the PALFINGER Group worldwide or in which the Group exercises a dominant influence. We encourage adherence to our Code of Conduct by all companies in which we hold a minority stake. We are all responsible for following and putting these standards into action.
Quick Guide
A brief summary of the most important rules of the PALFINGER Code of Conduct:
- The Code of Conduct and the standards defined therein must always be adhered to.
- Comply with legal and ethical standards in your area of responsibility and exemplify our values on a daily basis.
- Remember when you take action:
- Am I violating laws or internal regulations?
- Would I feel comfortable if my actions were on the front page of a newspaper?
- Do I act the way I would like to be treated myself?
- Misconduct can be reported to your respective manager, the HR department or the Integrity Line.
- If you have any questions, please contact PALFINGER's Governance, Risk & Compliance (corp.grc@palfinger.com) department.
