Compliance guidelines

1. Definitions and scope

Compliance means adhering to laws, regulations and internal instructions. This guideline applies to all employees and board members of the RSG Group in Europe, hereinafter referred to as employees.

2. Information | Obligation

Compliance means adhering to laws, regulations and internal instructions. This guideline applies to all employees and board members of the RSG Group in Europe, hereinafter referred to as employees.

3. Basic conduct requirements

Every employee is obliged:

to comply with the laws, regulations and internal instructions applicable in his area of responsibility
to act fairly, respectfully and trustworthy in all activities and business relationships
to respect and promote the reputation of the RSG Group
to avoid conflicts of interest between business and private matters, not to obtain unlawful advantages for oneself or others
to comply with the laws and regulations on occupational safety, environmental protection and data protection
Immediately report compliance violations to the Compliance Officer (Section 17). In addition, every supervisor is obliged to comply with the management principles of the RSG Group
to judge employees only on their performance and to ensure compliance with this policy in their area of responsibility.

4. Equal treatment

Discrimination on the grounds of race, ethnic origin, gender, religion, ideology, disability, age or sexual orientation is strictly prohibited. This applies in particular to dealings with colleagues, employees and business partners as well as to the hiring, promotion or dismissal of employees.

5. Prohibition of bribery and corruption

Fair play is not only a golden rule in sport, but also in the business environment. Corruption contradicts the principle of fair play and damages competition. This does not correspond to our corporate values and exposes RSG Group and each of its employees to unnecessary liability risk.

It is strictly forbidden:

to offer, promise or grant a personal benefit to domestic and foreign public officials in connection with their official position for the performance or omission of an official act (example: In order to speed up the approval process for a building permit, employee X offers the responsible administrative officials in the building authority to host an exclusive event at THE REED)
Offering, promising or granting unlawful personal benefits to employees or representatives of domestic or foreign companies (example: employee X promises to give the employee of a logistics company one of the devices for private use)
unlawful acts of other people (Example: Employee Y learns about the above examples and creates documents to cover up the misconduct of colleagues)
to have unlawful acts carried out with the help of others, for example relatives, friends, agents, consultants, planners and intermediaries (Example: Employee Y asks her friend, who works in a management consultancy, to create documents that describe the above – make misconduct seem plausible)
to demand or accept unlawful personal benefits (example: employee Z has two offers from different tilers. Although he knows that service provider A would be suitable for the job, he commissions service provider B, since the latter promises to offer employee Z’s private bathroom cheaper to rehabilitate).

6. Invitations, gifts and events

Invitations and gifts are part of polite human interaction. The employees of the RSG Group may extend invitations and give gifts to business partners and accept invitations and gifts from them, provided these are within reasonable limits. As a benchmark for assessing a reasonable framework, a pecuniary benefit of up to EUR 50.00 gross.

In order to avoid even the appearance of corruption, the following rules apply:

Employees of the RSG Group must refuse invitations and gifts if they are obviously or presumably connected with a specific expectation of some kind of consideration.
You must also refuse invitations and gifts if accepting them would violate the law or internal directives.
Employees of the RSG Group may not request any benefits. The same applies to the granting of benefits.
Participation in special events by employees of the RSG Group is permitted and encouraged. The same applies to the implementation of special events.
Invitations to and participation in social, corporate and leisure events in the business environment are permitted if they are within reasonable limits. Under no circumstances should they even give the impression of damaging fair competition or confusing interests.

7. Avoiding conflicts of interest

Each employee must strictly separate his private interests and the interests of the RSG Group. Even the appearance of a conflict of interest must be avoided.

In order to achieve this, the following orders may only be issued and the activities may only be carried out if they have been approved in advance by the responsible manager:

Orders to close persons (e.g. spouses, relatives, friends and private business partners)
Orders to companies in which related persons work
Orders to companies in which related parties hold 5% or more
Secondary employment for competitor companies
Secondary activities for business partners (e.g. mini job or influencer activities)
Employees who want to participate directly or indirectly with 5% or more in a competitor company or already have a stake must report this to the Compliance Officer in writing
If there are any doubts as to whether there is a conflict of interest, the compliance officer must be involved.

8. Fighting money laundering

The RSG Group only works with reputable business partners who act within the framework of the legal regulations and do not use any illegal funds.

Every employee must comply with the laws against money laundering and immediately report any suspicions that indicate money laundering to the respective head of accounting and the compliance officer (example: Employee Y learns that a business customer has gotten into financial difficulties. With the next invoice “Customer” pays with cash, Employee accepts the money and deposits it manually at the bank).

9. Foreign trade and export control

The RSG Group observes the legal norms of national and international law relevant to export controls and thus lives up to its role as a global group.

Permission requirements for the export of our products must be strictly observed. Export and support bans must be observed without exception.

The currently applicable customs regulations must be observed both when exporting and importing goods. If necessary, the purchasing department must be consulted in advance.

10. Collaboration with customers and suppliers

The management of the RSG Group expects from employees, customers and suppliers:

compliance with all applicable laws
refraining from corruption
respect for human rights
compliance with child labor laws
compliance with the legal provisions of international trade, in particular compliance with export and import bans and embargo regulations (example: Employee Y suspects that the missing information on a product in the target country of distribution is insufficient. In order to not endanger the business, Y nevertheless arranges for the transport).
protecting the health and safety of all employees
compliance with the relevant national laws and international standards on occupational safety, environmental protection and data protection

and that these points are also implemented and complied within our own supply chain.

11. Occupational safety and environmental protection

In the interests of the health and safety of all employees and visitors, every employee must comply with applicable occupational safety laws, regulations and standards in their workplace.

Every employee shares responsibility for environmental protection in their area of work and is obliged to comply with laws, regulations and standards on environmental protection.

12. Data protection

As an international company, the use of modern information and communication technology is an essential part of business processes for the RSG Group.

Employees are obliged to handle personal data sensitively in all business processes. Personal data may only be collected, used and stored in accordance with the applicable data protection laws. This applies to employee data as well as data from customers, suppliers, competitors and other people (example: Employee X goes on his lunch break and leaves his laptop switched on without a lock. After the break, he discovers that sensitive data records from his mailbox have been sent to a foreign e-mail address were sent).

In particular, data processing may only take place if the person concerned has given his or her prior consent or if this is legally permissible for other reasons. Personal data is to be used sparingly, and it must be processed in any case.

To ensure effective data protection, the RSG Group has appointed data protection officers and issued corresponding guidelines. If necessary, the legal department and/or data protection officer must be involved beforehand for the specific handling of personal data.

13. Protection of company assets

Every manager must establish an organization in his/her area of responsibility that protects the company’s assets from loss and misuse. The company’s assets must not be used for private purposes (example: manager Y wants to reward the hard work of employee X and leaves the company credit card to him for private use).

The purchase or sale of company assets must be transparent, comprehensible, economical and at fair market conditions. Personal interests of individual employees must not influence decisions and economic transactions.

Company and business-related data must be treated confidentially and may only be used within the scope of the area of responsibility.

14. Behavior towards competitiors

Competition law and antitrust law must be observed:

No prices, quantities and conditions may be exchanged or agreed with competitors (example: employee X agrees with K and L, who each work for other competing companies, that a price adjustment of 15% in the next quarter appears to be “in line with the market”).
Agreements with competitors on market sharing are not permitted

These rules must also be taken into account in association work. Industry statistics without the identification of individual companies are permissible.

15. Donations and sponsorship

The RSG Group makes monetary and in-kind donations for non-profit and charitable causes such as education, science, art, culture, sports and social causes.

Donations may only be made with the prior approval of the respective management in accordance with the applicable rules of procedure.

The RSG Group also acts as a sponsor of events and projects for the benefit of the non-profit and charitable purposes mentioned.

Sponsorship and donations must be made in accordance with applicable laws and the above regulations to prevent corruption and conflicts of interest and to protect company assets (example: Employee X “blocks” a large area in the fitness club so that his friend can host a promotional event for their start-up company).

16. Consequences of compliance violations

For employees, compliance violations can have the following consequences:

Warning
Termination
Claims for damages by third parties and the RSG Group
Fine and penalty
Imprisonment.

Compliance violations can have the following consequences for the RSG Group:

Claims for damages by third parties and cost-intensive court proceedings
Fine and confiscation of profits
Loss of image.

17. Contact person and compliance officer

If you have any concerns or questions:

talk to your supervisor or the responsible department, for example the HR department for employment contract issues.
If clarification with the supervisor or the responsible department is not possible or if concerns persist, the Compliance Officer is available as a contact person.
the Compliance Officer can be addressed directly at any time, confidentially and anonymously if desired.

Via the whistleblower platform provided, it is possible to anonymously report suspected cases relevant to compliance.