ESG & Code of Conduct

Our Purpose and our Mission – we care about our ESG and follow our Code of Conduct.

We help our global partners focus on investing and preserving capital in a sustainable and compliant manner.

• We are a trusted partner providing high quality personalised services
• We help our customers and the sector to stay compliant
• Our people invest the time to get to know our customers, so that we know how to best service them

Our ESG underpins PLEUGER Industries´ activities across all jurisdictions where we or one of our affiliates operate. It sets out our global approach to sustainable purpose and forms the basis of our decisions by focusing on business ethics and compliance, people and culture and community involvement.

Business ethics and compliance framework

At the core of this framework is strong governance and a robust risk and compliance framework. This framework is supported by procedures and systems to ensure that we apply, at all times, high levels of personal and professional integrity. With the support of our risk and compliance function we have put in place the necessary policies and procedures including a code of conduct and an initial assessment of the reputation of potential customers, identification and monitoring of our customers (through initial and ongoing screening of customers, ongoing review of customers files and transaction monitoring) as well as ongoing training throughout our employees’ careers to ensure  that the highest standards of compliance are embedded right across our Group operations.

We will not enter into, or maintain, relationships with individuals or organisations engaged in, or suspected of having engaged in, illegal or activities which go against its code of ethics. New customers are accepted in accordance not only with applicable laws, rules and standards on money laundering and terrorist financing, and international sanctions but also in accordance with our risk appetite policy. We do not accept customers activities involving money laundering, corruption or bribery, child labor, forced labor, the mining and trade of rough diamonds unless Kimberley certified, destruction of high conservation value areas, ship breaking, products or activities that impinge upon the lands owned or claimed under adjudication by indigenous and/or vulnerable peoples or groups without full documented free prior and informed consent (FPIC) of such peoples or groups.

Our customer acceptance processes include a mandatory review of our customers’ activities to ascertain they are not involved in such activities.

People and culture

Fostering openness, sustainability, and respect are our key objectives. We value everyone and strive to work as one team. We invest significantly in our people and their working environment by creating and maintaining a safe and healthy working environment and ensuring their ongoing professional and personal development.

We strive to create workplaces in which there is mutual trust and respect and where every person feels responsible for the performance and reputation of our Group. We respect one another and each other’s individual rights and customs. We work towards achieving a diverse workforce, recruiting, employing and promoting people only on the basis of objective criteria and the qualifications and abilities needed for the job to be performed.

We continuously engage with our people at a local and at a Group level to translate our core values into action. We do this through communications and engagement, information and consultation so as to assist them in realising their full potential.

We promote integrity and professionalism throughout the Group and pride ourselves in leading by example which we do by setting the right tone right from the top of our organisation. We consider ourselves to be personable and approachable and hold these attributes up as being key when putting our core values into actions.

Corporate Social Responsibility

We encourage our people to give something back to their local communities, whether it is time, effort or a financial contribution. Our key focus areas are the community, health, education and the environment. It’s important that we play our part to build a better world for current and future generations. Our support is delivered through initiatives that:

• Support local communities and those in need;
• Support local initiatives for the development and education of young people in the areas we live;
• Support our environment and reduce our carbon foot print.

We welcome initiatives from all sources but especially those from our own people.

Ethical Business Code of Conduct at Pleuger Industries

Preamble
All employees are bound by the provisions of this Code of Conduct. It sets out the values, principles and actions that determine Pleuger Industries’ entrepreneurial actions. The goal Pleuger’s management is to comply with ethical standards and to establish a working atmosphere that encourages integrity, respect and fair behavior. A strictly law and principle-abiding business policy serves the company’s long-term interests.

This code of conduct has been adopted by the management of Pleuger Industries and approved by the owner.

Compliance with laws and other regulations at home and abroad

In all business decisions and actions, Pleuger Industries endeavors to observe the applicable laws and other relevant regulations at home and abroad. Integrity and honesty promote fair competition, also in relation to our customers and suppliers.

Prohibition on Modern Slavery and Human Trafficking

Pleuger Industries is committed to conducting its worldwide business operations in a manner that complies with applicable laws and regulations and according to the highest ethical standards. Pleuger Industries prohibits slavery and human trafficking and is committed to taking steps to ensure that slavery and human trafficking is not taking place in any part of our supply chain or business.

Company Management Commitment

Pleuger Industries sees itself obliged to act economically, socially and environmentally consciously. Pleuger Industries therefore strives to conduct its business in a competent and ethical manner and to protect fair competition in all markets in which it works by complying with applicable laws on prohibitions of cartels, competition and restrictions of competition. Unfair advantages, rival customers, suppliers or competitors are to be avoided.

Conflicts of Interest

Pleuger Industries expects its employees to be loyal to the company.

All employees must avoid situations in which their personal or financial interests’ conflict with those of Pleuger Industries. Therefore, engaging with competitors, vendors or clients or entering into company interactions with them in a personal setting is particularly forbidden if this could result in a conflict of interest. Conflict circumstances must not affect the interests of Pleuger Industries.
Such conflicts of interest can arise in many situations: For example, no employee may accept benefits – in any form whatsoever – that can be presumed from a reasonable point of view to influence business decisions or transactions of Pleuger Industries. Invitations must stay within ordinary company hospitality boundaries. Employees should not achieve direct and/or indirect benefits by accessing confidential data because of their role at Pleuger Industries. It is the responsibility of all employees to promote as far as possible the legitimate interests of Pleuger Industries. Any competitive situation with the company must be avoided.

Any actual or potential conflict of interest must be reported and discussed with the relevant superiors.

Prohibition of corruption

Pleuger Industries is against corruption and bribery. We will not tolerate behavior in which unfair means are used to conduct business. Pleuger Industries’ employees must not offer, receive or accept any benefits from business partners that might impair an objective and fair business decision or even create such an appearance.

Fair working conditions

All Pleuger Industries employees are responsible for ensuring a secure and healthy environment. Therefore, safety regulations and procedures must be strictly observed.

As a socially responsible employer, Pleuger Industries regards its employees as a great asset. It demands great commitment from its employees and in return, shares its business success with them.

The personnel policy of Pleuger Industries’s helps to give every employee the chance to develop both professionally and personally.

Open exchange of opinions, criticism and ideas are encouraged.

Pleuger Industries condemns illegal discrimination or harassment of any kind.

Dealing with internal knowledge

All Pleuger Industries employees are required to guarantee rapid and exchange of information within the company. Information shall be transmitted properly and fully to the proper areas, unless priority interests occur in outstanding cases, in specific due to confidentiality commitments. Relevant knowledge may not be illegally withheld, falsified or transmitted selectively.

Dishonest reporting within the company or to external organizations or persons is strictly prohibited. All financial statements and annual reports, business papers and accounts of Pleuger Industries must present business transactions and books accurately and comply with the legal requirements as well as the accounting principles and internal accounting procedures of Pleuger Industries.

Dealing with assets

All Pleuger Industries employees are responsible for the proper and cautious handling of the assets of the company. Each worker is required to safeguard Pleuger Industries’ assets from loss, harm, misuse, theft, misuse or destruction. Each worker has the obligation to immediately inform his superior of any use of assets contrary to the above.

Confidentiality and data protection

Much of Pleuger Industries’ business information is confidential or legally protected, so a secrecy requirement exists. This does not apply if Pleuger Industries has authorized a publication of the information or is mandatory due to laws or regulations.

Particularly, the duty of confidentiality refers to intellectual property. This includes trade secrets, patents, trademarks and copyrights, but also business and marketing plans, drafts, business papers, salary information, and all other unpublished financial data and reports.

Pleuger Industries uses and treats all personal information about employees, clients, business partners and suppliers as well as other third parties in complete accordance with data protection laws. This data must be protected with the utmost care.

Implementation and monitoring

The rules contained in this Code of Conduct are a key component of Pleuger Industries’s corporate culture. Uniform adherence to these values is essential. Every employee is responsible for this.

If an employee has concerns or complaints about the points listed in this Code of Conduct or is aware of any breach of the Code of Conduct contained therein, we encourage him to report immediately for clarification to his superior or the department of HR. This can also be done anonymously or in a confidential manner. If an employee is not satisfied with the result of the clarification, the concern or complaint may be submitted not only to the supervisor, but also to the management board or the works council. Pleuger Industries does not allow reprisals under this Code of Conduct for complaints made in good faith.

Responsibility

All employees of Pleuger Industries are bound by the rules of this code of conduct. Violations of this Code of Conduct have consequences. This can result in the termination of the employment relationship in severe cases.