UMS Code of Conduct (Version 2.2, July 2023)

UMS is committed to upholding certain core values related to human rights, labour standards, the environment and anti-corruption as part of its business policy. This Code of Conduct defines the basic requirements for our responsibility towards our stakeholders and the environment. 
This Code of Conduct is an integral part of any employment contract and is also made the subject of customer contracts. At the same time, we expect our contractors and suppliers to commit themselves and their employees to these values, standards and goals and to behave according the following regulations. This Code of Conduct supplements all current and future UMS policies.

1. Legal compliance 

• We comply with applicable national and international laws.

2. Conflicts of Interest 

• Employees shall at all times act in the best interests of UMS and wherever possible avoid situations in which their personal interests conflict with those of UMS. The interests of related parties (family members and other residents of the same household) may according to the circumstances also be regarded as personal interests of an employee.

3. Prohibition of corruption and bribery, gifts and grants 

• We do not tolerate any form of and do not engage in any form of corruption or bribery, including any payment or other form of bene fit conferred on any government official for the purpose of influencing decision making in violation of law.
• UMS is committed to the international struggle against money laundering. Employees in their work environments may neither allow themselves to become involved in nor tolerate actions in violation of domestic or foreign money laundering regulations.
• Our employees may not accept services, gifts, or advantages from any client or vendor that might influence personal behaviors while performing work-related tasks.
• Gifts and other grants (including discounts) from UMS business partners may represent, up to a certain value, customary business practices and might be legitimate means of developing and strengthening business relationships. Nevertheless they may entail potential conflicts of interest and place UMS’ reputation at risk. For this reason, acceptance of gifts and other grants is always prohibited if UMS’ interests are harmed or if the professional impartiality of the employee could be placed at risk, whether in actuality or appearance.

4. Recognition of basic human rights of employees 

• We promote equal opportunities for and treatment of our employees irrespective of skin color, race, nationality, social background, disabilities, sexual orientation, political or religious conviction, sex or age;
• We observe laws and regulations governing the equality of men and women. Without limitation, equality encompasses areas such as the assignment of duties, compensation, training and professional development as well as promotion.
• We respect the personal dignity, privacy and rights of each individual;
• We refuse to employ or make anyone work against his will;
• All employees are to be treated with dignity and respect; the privacy and personal rights of each individual are to be respected. No employee shall be subject either to physical punishment, threat of violence or other forms of physical, sexual, psychological or verbal violence;
• We prohibit behavior including gestures, language and physical contact, that is sexual, coercive, threatening, abusive or exploitative;
• We provide fair remuneration and to guarantee the applicable national statutory minimum wage;
• We comply with the maximum number of working hours laid down in the applicable laws;
• We respect the rights of all employees to form associations and assemble, as well as to respect collective bargaining.

5. Prohibition of child labor 

• We employ no workers under the age of 15.

6. Adequate labor conditions 

• We take responsibility for the health and safety of our employees;
• We offer our employees a safe and hygienic workplace, without any health hazards whatsoever;
• We provide training and ensure that employees are educated in health and safety issues;

7. Environmental protection 

• We act in accordance with the applicable statutory and international standards regarding environmental protection;
• We minimize environmental pollution and make continuous improvements in environmental protection;

8. Fair Competition 

• Our business activities are subject to the rules of fair competition. All employees observe the relevant antitrust laws and laws against unfair competition.

9. Confidentiality 

• During and after their employment with UMS, employees shall observe absolute secrecy concerning all trade secrets and all other confidential information about UMS and their business partners, which they may learn in the course of their employment relationship with UMS.

10. Intellectual Property 

• Our know-how and other intellectual property is of special importance for UMS` long-term success. Such intellectual property shall therefore be suitably protected in the best possible manner
• We respect patents, trademarks, know-how and other third-party intellectual property in every case.

11. Data Privacy 

• ustomer and employee data shall be treated with care and discretion. Processing and disclosure of such data is permitted only in compliance with legal requirements and any internal directives and shall be protected by commensurate technical and organizational measures.
• We have appointed a data protection officer who should be contacted if you have any questions about data protection or in case of violation of data protection.

12. Complying with the code 

• We use reasonable efforts to promote among our cooperation partners compliance with this Code of Conduct;
• We comply with the principles of non-discrimination with regard to supplier selection and treatment.
• In the case of non-performance of the Code, we reserve the right to request appropriate corrective action from our partners and, if required, to end the cooperation.
• The Management of UMS shall adopt the appropriate resolutions to fully implement the Code of Conduct. The Management is further responsible for monitoring and enforcing compliance with the Code of Conduct and, if necessary, for implementing special monitoring programs.

13. Notification of compliance violations 

• We would like to be informed about illegal behaviour in our company in order to be able to investigate and stop such behaviour. We therefore encourage everyone - whether employees, former colleagues, customers, suppliers or third parties - to inform us of any violations of the law.
• We guarantee all whistleblowers confidential treatment. Employees should first contact their supervisor. We understand that this does not seem opportune in all cases. Therefore, anyone can also contact the Chief Compliance Officer directly or use our whistleblower portal (whistleblower@ums-gmbh.com). You can also use this portal to send information without mentioning your name. However, we would ask you to set up a mailbox under at least one other name that does not allow any conclusions to be drawn about you, so that we can contact you with questions.