Code of Conduct
Responsible, ethically correct, and lawful behavior is just as fundamental to the success of the JECTURE Group as our innovative strength, technical performance, quality, and customer focus. The reputation we have earned with our customers, shareholders, business partners, employees, and the public through our commitment can be severely damaged by individual breaches of the rules.
Our common goal is to further strengthen the JECTURE Group as an expert in the development and production of medical cannulas and cannula systems. Therefore, each of us is required to act responsibly and in accordance with applicable laws. This Code of Conduct sets out the ethical and legal framework within which we operate. It defines the fundamental principles for our behavior within the JECTURE Group and in relation to our partners and the public. It sets out the principles of our corporate behavior and is an expression of our understanding of values.
Acting responsibly means acting lawfully and ethically. These principles of behavior are the binding standards and framework for the actions of all employees. Our Code of Conduct does not exempt anyone from their personal responsibility. However, we encourage all employees to seek advice and help in confidence at any time when it comes to decisions on ethical or legal issues or become aware of behavior in their working environment that they consider difficult or questionable. The only business conducted here is JECTURE Group business. The Compliance Office bridges the gap between law, conscience, and culture.
Our Code of Conduct serves as a guideline for behavior that aligns with and sustainably shapes the corporate culture of the JECTURE Group. It is based on integrity, safety, respect, and sustainability. The binding principles of conduct are designed to protect our employees, managers, and the organizations behind them. The Code of Conduct is intended to help answer ethical and legal questions that arise in day-to-day business, strategic considerations, and decision-making processes correctly and appropriately.
All employees are called upon to live by the principles of behavior at the JECTURE Group on a daily basis.
Cooperation with customers, suppliers, and business partners
Business relationships with our customers, suppliers, and business partners are governed by ethical behavior. We run our company in an open, honest, and ethically responsible manner. Our actions are always characterized by fairness, good faith, and integrity. We say what we mean and do what we say. We expect the same from all employees and all persons with whom we do business.
Avoidance of conflicts of interest
We do not maintain any relationships with customers, suppliers, or competitors that could influence our decisions on behalf of the JECTURE Group. Actual or potential conflicts of interest must be avoided.
Our employees avoid conflicts between their private interests and those of the company. We are not guided in our decisions by private interests or personal relationships. Business relationships are based on objective criteria, including price, quality, and the existence of a fair, established working relationship. Relationships from which purely personal material or immaterial benefits are derived must not influence the conclusion of a contract, or the continuation, or termination of a business relationship. The JECTURE Group welcomes any voluntary commitment by its employees that is compatible with fulfilling their contractual obligations to the JECTURE Group. Private expressions of opinion by employees in public must not give the impression that they represent the position of the company.
If an employee is involved in an actual or potential conflict of interest, this must be reported immediately to the line manager and/or the Compliance Office and resolved together with them.
No dependencies
We make our decisions freely and independently, without allowing relationships of dependency to develop. We do not permit ourselves to be influenced or favored by suppliers, service providers, or customers. Material or moral dependencies must not play a role in our dealings with business partners.
We reject a business policy in which „one hand washes the other“. Invitations from business partners to events or business meals are only accepted if there is a clear business reason. The invitation must be appropriate relative to the business partner and should not exceed customary hospitality.
Gifts from business partners must comply with legal standards and be appropriate in type and scope. Invitations from business partners to events of a predominantly private nature are allowed only in authorized exceptional cases, provided the relevant costs are covered by the JECTURE Group or the employee themselves.
Fair competition
We are committed to fairness in competition. The market can only develop freely in fair competition. Every employee of the JECTURE Group is obligated to observe and comply with the rules of fair competition.
Wherever the JECTURE Group operates, the company adheres to antitrust and trade laws, laws on pricing, competition laws, and consumer protection laws. JECTURE Group employees must always act within the legally permissible framework when dealing with customers, suppliers, and competitors. This means that they may not enter into price agreements or secret agreements on production, supply, or market sharing. Employees of the JECTURE Group must not participate in unfair trading practices.
We do not tolerate the conclusion of unlawful agreements with competitors. Even the appearance of unfair agreements with other market participants must be avoided. In cases of doubt, the Compliance Office must be consulted.
No corruption and bribery
We are committed to integrity in our business and social activities. Decisions on business transactions with our partners are based exclusively on neutral, assessable facts such as quality, price, and performance. They are not influenced by gifts, donations, bribery, or corruption. The principles of honesty and integrity must be observed in all business and social activities.
Relationship management is integral to business success. It does not operate in legal grey areas nor is it pursued by improper means. Employees of the JECTURE Group neither directly nor indirectly accept bribes nor offer them. Bribery is a criminal offence in business dealings as well as towards public officials. When dealing with government bodies or authorities, no payments or benefits are promised or granted to influence decisions by officials or other public officials in favor of the JECTURE Group. We do not give gifts to improperly influence our market position, nor do we accept gifts intended to stimulate contract awards. Gifts and benefits that could influence business decisions must be avoided and may not be offered, granted, demanded, or accepted. This applies particularly to the initiation of orders and the conclusion of business deals, even if they could merely create the appearance of influence.
As a responsible member of society, the JECTURE Group makes monetary donations and donations in kind for education, culture, social causes, and sport. The allocation of donations must always be transparent. The recipient of the donation and its intended use must be known and traceable.
Donations to individuals, profit-oriented organizations, and organizations that pursue a non-tax-privileged purpose are prohibited, as are donations to private accounts and those that could damage the reputation of the JECTURE Group. Political donations to individuals, parties, or other political organizations are excluded. The JECTURE Group may provide donations, either in cash or in kind, for an event organized by a third party. This is referred to as sponsorship if the services provided are linked to a consideration in the form of advertising or customer loyalty measures. Sponsorship requires a written contract, a serious business purpose, an appropriate relationship between donation and consideration, and complete transparency.
Donations and sponsorship funds that exceed local and temporary activities or small donations are decided exclusively by the management of the JECTURE Group.
No violation of market restrictions
We respect all national and international customs laws as well as foreign trade, anti-terrorism, and embargo regulations. All employees are obliged to comply with the restrictions and prohibitions on the foreign and domestic trade in certain goods, services, or technologies. Trade bans and restrictions related to international embargoes and the international fight against terrorism, which may also affect capital and payment transactions, must be observed. National (German) and European export control regulations are decisive for us.
If doubts about the authorized use or transfer of our products cannot be resolved, a decision must be made by the Compliance Office and the management.
Ensuring product safety and product quality
All employees are fundamentally responsible for ensuring that customers can trust the safety and quality of our products. Product and process safety is our top priority. We select our suppliers based on the safety of their products and their compliance with quality standards.
We have developed professional product safety policies and programs based on sound scientific principles, practical operating procedures, the latest technologies, employee training, and customer education.
The products we sell not only fulfil the legal requirements and industry standards/guidelines, but in most cases exceed them. Every employee is responsible for product safety. It is important to us to consistently meet our customers’ expectations.
Protection of company assets
The material and intellectual property of the JECTURE Group must be protected against loss, theft, and misuse. Our corporate value is based on the ideas and creative power of the people who are committed to the success of the JECTURE Group, both past and present. Successful knowledge management has perpetuated this added value over many years. Inventions, patents, names, and other expertise are as valuable as our brands. We protect these intangible assets because they are of considerable economic importance for the future of our company. We are committed to respecting the material and intellectual property of third parties and reject unlawful ways of obtaining information. Trade secrets include all non-publicly accessible information that is of significant importance to the JECTURE Group or its competitors, as well as any information exclusively available to the company.
Secrecy
We take great care to protect confidential information. Company secrets and future knowledge must not be passed on to third parties or made public without legal protection. Confidential information includes documents, facts, data, and knowledge relating to profit figures, new products, ideas for research and development, business or marketing strategies, customer insider information, personnel matters, investments and shareholdings, manufacturing processes, and internal policies and procedures. No employee may misuse intellectual property of the JECTURE Group for their own purposes. All employees are required to protect data from unauthorized access by third parties and to safeguard business documents. IT security, data security, and data protection are high priorities.
Property and facilities of the company
We respect the company’s property and facilities and treat them with care. Assets and funds of the JECTURE Group may not be used for unlawful purposes.
Production areas, laboratories, offices, and workplaces must be kept clean and tidy at all times. We use the equipment provided by the company, e.g. telephones, company cars, and computers, in accordance with local JECTURE Group policies.
Computers provided to employees by the company and the data stored on computers are the property of the JECTURE Group. Inappropriate use of computers is not permitted. Personal use should be appropriate and kept to a minimum.
Reliable communication
Transparent, timely, and reliable internal and external communication is an important part of our corporate culture. Misinformation from employees and colleagues, the general public, the market, and our customers is not acceptable to us.
Customers should be given appropriate access to the information they need to make a sound business decision. This can be done, for example, through general written product information or through sales staff. The JECTURE Group takes customer complaints very seriously and addresses them promptly and fairly.
All information provided to the public must be truthful. Error-free quality is our standard. Inappropriate, misleading, incomplete, or careless statements can be misinterpreted, misused, or taken out of context, potentially causing significant damage. Therefore, communications via email and new media must also be conducted accurately. In principle, information may only be communicated to the public via authorized employees. Anyone who appears publicly as a representative of the JECTURE Group without being authorized is acting as a private individual.
In the event of enquiries from investigating authorities (e.g. police, tax investigation, public prosecutor’s office), the Compliance Office must be involved immediately.
Transparent accounting
Key business processes are appropriately documented in the accounting system. The systems used ensure that accounting-relevant information on business transactions is recorded completely and correctly. Complete, clear, and comprehensible document and file management is a standard practice for us. Records and files must be maintained in a way that allows auditors and tax authorities to understand their system and content at all times. Our processes are transparent and structured so that other employees can continue them seamlessly. Legal and internal retention obligations must be complied with and documents related to official or legal proceedings must not be destroyed.
All documentation must be formally correct and consistent in terms of content so that it can be presented to third parties if necessary.
Behavior in the workplace
The behavior of every employee shapes the public perception of the JECTURE Group. We therefore demand appropriate and respectful behavior towards colleagues, employees of suppliers, customers, and other business partners.
Equal rights
We are committed to treating each other with respect. Our employees are the foundation of the JECTURE Group’s success. To allow their strengths to develop, we create a working environment that values appreciation and promotes integrity.
We do not tolerate discrimination or harassment. Regardless of age, origin, gender, or race, what counts for us is performance and cooperative behavior. Regardless of political commitment, religion, physical constitution, or sexual identity, we judge work results objectively. There is no room for slander, intimidation, threats, or accusations. Fairness, respect, team spirit, and openness characterize our cooperation with superiors, colleagues, and employees. These principles also apply to our behavior towards external partners. We respect and promote employee rights and pursue a partnership-based and solution-orientated approach with our employees.
We specifically promote cross-divisional and cross-national cooperation. The decisive criteria for the selection and promotion of our employees are performance, development potential, and personal qualifications. We are committed to a culture of learning in which objective feedback is valued by everyone involved, and personal attacks are rejected.
No drugs and no alcohol in the workplace
We always behave professionally and appropriately. Our work requires clear thinking and often quick reactions; the safety of colleagues and consumers depends on it.
Alcohol, drugs and excessive medication impair an employee’s performance. We strictly follow workplace policies on smoking, alcohol, and drug use.
Health and safety
The JECTURE Group promotes safety and health-conscious behavior to protect the lives and health of its employees, preserve its assets, ensure business continuity, and build public trust. All JECTURE Group companies are committed to providing a safe and productive working environment for their employees. Safety is particularly important in production areas, which have their own safety regulations. Specific safety rules have been established for each workplace and must be followed. JECTURE Group companies comply with all applicable health and safety legislation and often exceed required criteria.
Human rights
We respect the principles of the Universal Declaration of Human Rights. We strongly condemn forced labor, child labor, and all practices in which people are exploited or exposed to dangerous conditions.
We strictly adhere to the applicable laws governing the minimum age for employment and other conditions of employment. The minimum age of employment at JECTURE Group complies with the International Labor Organization Convention or the age prescribed by local legislation, if higher.
Environmentally sound business practices
We are committed to sustainable entrepreneurship. We comply with applicable environmental laws and regulations. We are committed to improving environmental performance by supporting the transfer of expertise, best practices, and technology. We endeavor to minimize the impact of our business activities on the environment by using energy and water resources sparingly, handling consumables carefully in our day-to-day work, monitoring air pollution, limiting the use of packaging, and minimizing waste generation.
Contribution to sustainable economic and social development
Our social responsibility extends beyond our supply chain to encompass all aspects affected by our business. By interacting with the relevant parties (suppliers, customers, consumers, employees, and communities), we ensure that the JECTURE Group’s social activities effectively support improvements, taking local conditions into account and are beneficial to both the company and the community. We collect data on environmental impact and performance, establish monitoring principles, and regularly review progress. We require our suppliers to systematically improve the social, environmental, and ethical quality of their products and production processes and support them in their efforts.
The JECTURE Group actively promotes the communication of the corporate guidelines and agreements on which the Code of Conduct is based. The company ensures their implementation and guarantees that no employee suffers any disadvantage for complying with the guidelines or agreements. Our managers serve as role models, with their actions measured against the Code of Conduct. They are the first point of contact for questions about understanding the regulations and ensure that all employees know and understand the Code of Conduct. As part of their management role, they prevent unacceptable behavior and take appropriate measures to prevent rule breaches in their area of responsibility. Trusting and good co-operation between employees and managers is demonstrated by honest and open information and mutual support.
For further questions relating to the Code of Conduct, the central email address coc@jecture.com is available to all employees and third parties (customers, suppliers, etc.). Information on possible violations of the law or guidelines in the areas of antitrust law or guidelines in the areas of antitrust law and corruption affecting persons and companies of JECTURE Group GmbH can also be reported via the JECTURE Group GmbH Whistleblower Portal. The corresponding link is available on the JECTURE Group website. All information is treated in strict confidence.
Jecture GmbH
Philipp-Reis-Straße 2
36399 Freiensteinau