Ethics Policy

Mission Statement

For a continuously growing, medium-sized family business, maintaining a uniform corporate culture is elementary. The owner family and the employees of the Wiebe Group are therefore striving to develop a high-performance, stable and socially responsible company.

All employees are therefore obliged to deal openly, honestly, fairly and trustfully with clients, business partners, subcontractors and colleagues. The values of our society, the principles of orderly business and technical progress for the well-being of all are thus effectively taken into account. This culture of responsible, entrepreneurial and social action is specified by the Ethics Policy and the procedures for its implementation.

Policy

The Ethics Guideline is intended as a framework of orientation to ensure business conduct with integrity in the long term and contains clear rules of conduct according to which we orient our actions and decisions.

The ethics guideline deals with five areas related to entrepreneurial, company-specific behavior. The rules formulated in it are intended to be both a constant appeal and an incentive for value-oriented behaviour.

The ethics guideline also includes instructions for implementation, which show understandable and unambiguous limits for certain areas and require compliance with them.

Our competencies at a glance

Cooperation with each other

The cooperation is characterized by respectful and trusting interaction with each other as well as the acceptance of other opinions. Our communication is always open and honest. We ensure a working environment free of discrimination or harassment. We treat business information and trade secrets sensitively and confidentially.

Cooperation with clients

We convince the competition with professional conduct and high-quality work. We do not promise personal benefits or benefits at any stage of the collaboration. All documents and records are prepared in accordance with the obligation and are not changed, destroyed or otherwise manipulated for unfair reasons.

Cooperation with subcontractors, suppliers and business partners

Contracts are agreed realistically, unambiguously and by mutual agreement. The contact is always in the sense of an equal, cooperative and fair manner. All employees will refuse money, gifts of value or other benefits if they only give the impression that our decision is influenced or exceeds the usual orders of magnitude and number of normal business relationships. Actions and decisions are free of irrelevant arguments and personal interests. Private and personal concerns are always separated.

Possible conflicts of interest (e.g. relatives) that could influence our objectivity are avoided as much as possible, otherwise disclosed.

Cooperation with supervisory authorities

In cooperation with the authorities, we observe compliance with the applicable laws and regulations and actively cooperate with their representatives.

Behaviour in society and the environment

All employees respect human rights, national laws, regulations and religions. Unethical or illegal business practices will be rejected.

Ensuring safe, environmentally and health-friendly working conditions is a constant task and obligation.

Application and validity

The Code of Ethics applies to all employees of the Group and its affiliates. Subcontractors and suppliers are also involved by means of corresponding, explicit references or contract formulations. The guideline will apply to all employees of the Wiebe Group from the date of its publication.

Final provisions

Failure to comply with these laws, regulations, values and norms covered by the directive can result in consequences under employment law for the employee in a specific case, which can go as far as dismissal without notice. Furthermore, there is also a risk of criminal prosecution and the assertion of claims for damages in the event of violations. Business partners run the risk that business relationships will be terminated immediately in the event of violations.

Implementation and explanations

The ethics guideline is to be adhered to and repeatedly addressed. Their implementation is supported by the following three measures .

However, these aids and rules cannot record every possible situation that can occur in everyday professional life. Through our own personal behavior and loyalty, we contribute to the implementation in a positive way.

Have I informed colleagues and superiors and coordinated with them or sought advice?
Is the action/decision in accordance with standards and the law?
Am I endangering the integrity/reputation of the company, the client or myself?
Would the decision be reviewed neutrally, would it be objectively approved?
Does the course of action damage your own company?

(A) Self-control by answering the following questions

Due to decentralization, the “construction sites” have a high degree of independence, but also of personal responsibility. The answers to the following questions are intended to provide concrete and supportive assistance if difficult questions, doubts or uncertainties arise with regard to the voluntary commitment made to this guideline:

(B) Contact and communication support

In all matters relating to this ethics management and its compliance, every employee should first seek clarification within the given organization of the group of companies.

If this is not possible or appropriate, a separate mailbox has been set up to support communication outside the “usual official channels and in the event of problems”, which has been expressly installed for requests, messages, suggestions, criticism, complaints, etc. and grants neutral access to all persons or companies.

The information received here will be registered exclusively by the internal audit department, treated confidentially and, depending on its content, given anonymously to the affected management departments for processing. If these reports contain sufficiently justified indications of potentially damaging conduct, IR will investigate the matter immediately with due diligence.

The investigations have the following aim: Objective clarification and assessment of the facts with the result:

Relief and protection against incorrect allegations or
consistent evidence of actions that damage business.

The shareholders and management of the holding company are informed at least annually about the number of reports received and the facts presented in them. Regardless of this, the proper and timely involvement of the executive bodies of the companies concerned in any necessary personnel decisions or measures is required.

The company’s own P.O. Box has been set up at the P.O. Box address 33 01 52 in 28331 Bremen.

(C) Code of Conduct, Regulations and Value Limits

Grants

The acceptance of donations of any kind from business partners, both paid and gratuitous, is prohibited. An exception is customary, non-regular advertising or courtesy gifts (e.g. annual calendars), the value of which does not exceed €30.
Invitations to dinner are permissible within the framework of the usual and ordinary cooperation if the invitation is voluntary.
Participation in intended customer events must be reported to the supervisor.
Sponsorship of events of the companies of the Wiebe Group or parts thereof by business partners is subject to approval. Donations are only made on a voluntary basis and without expectation of anything in return.

Gifts of any kind to business partners are not permitted if their business conduct can be influenced by them.

Company Assets

As part of their work, all employees are obliged to protect the assets of the group of companies and to act honestly, responsibly and with integrity in dealing with them.
All property of the Wiebe Group is only to be used for operational or approved purposes and must be treated with care and care. All employees are required to protect property from loss, theft, damage or misuse.
All business documents, work materials and other documents as well as transcripts, copies and electronically stored data made thereof must be carefully stored and returned without being asked to do so upon termination of the employment relationship.

Expenses and construction funds must be prepared and accounted for according to actual expenditure with receipts in accordance with the applicable regulations.

Price fixing

Illegal agreements or other illegal activities that can influence prices and other conditions or hinder free and fair competition in an impermissible, restrictive manner are prohibited.

Conflicts of interest

Possible conflicts of interest must be avoided. If circumstances arise that make them unavoidable, they must be notified. The notification must be made to the supervisor immediately after recognizing a circumstance for a possible conflict of interest. The supervisor decides on appropriate measures to avoid ties and overlaps. Conflicts of interest are in particular:

Investments in subcontractors, suppliers, customers or other companies with which the Wiebe Group maintains or intends to establish business relationships.

Employees' own construction activities (e.g. house construction), provided that their contract value exceeds the sum of €10,000.

Intended, private commissioning/employment of a company or the staff of the Wiebe Group of Companies in one's own name and for one's own account.

Confidentiality

Confidential business information, trade and trade secrets may not be disclosed or passed on to third parties.

The use of such confidential information to the detriment of the Wiebe Group, for one's own benefit or for the benefit of third parties is prohibited.

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