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Code of Conduct

Our Code of Conduct forms the foundation for responsible and respectful behavior across the entire group of companies. It defines the shared values and principles that guide our daily interactions as well as our collaboration with customers, partners, and society. In doing so, we create transparency, build trust, and provide clear guidance for our actions.

 

1. The Code of Conduct of the Horn & Co. Group

We expect respectful interaction at every level and actively promote this standard in our relationships with customers and suppliers. The Horn & Co. Group is committed to equal opportunities, appreciation, trust, and performance. We foster a culture of mutual trust, respect, and open dialogue.

2. Commitment for All Employees

All employees are expected to adhere to this Code of Conduct and to actively contribute to its implementation, enforcement, and further development. Our managers are responsible for ensuring that employees understand this Code, creating opportunities to discuss it, and communicating its importance.

3. Law, Society, and Environment

As part of our social responsibility, we comply with legal requirements and, beyond that, uphold our responsibility toward the law, society, and the environment.

a) Equal Opportunities / Anti-Discrimination

We respect the Universal Declaration of Human Rights and act accordingly. Furthermore, we do not violate any legally established rights of our employees or of any individuals we interact with in the course of our business activities.

In hiring and employment practices, as well as in all business activities such as trade, we do not discriminate on the basis of race, skin color, gender, religion, political opinion, national origin, social background, disability, sexual orientation, or any other characteristic.

We do not tolerate child or forced labor in any area of our business activities. Furthermore, we do not engage in business with partners who are involved in child or forced labor.

Our actions are based on the principles of equal treatment and non-discrimination.

b) Compliance with Legal Regulations

In order to meet society’s expectations and as a fundamental basis of trust, all managers and employees of the Horn & Co. Group do not regard compliance merely as adherence to rules. Instead, we see it as a social responsibility and conduct our daily business activities in accordance with applicable laws and ethical standards.

The individual companies within the group are free to implement stricter internal regulations within the framework of applicable laws. Employees are required to comply with these stricter internal policies.

Employees who obtain prior knowledge of violations within the company are granted special protection. We take whistleblower protection requirements seriously and ensure that employees who report concerns in good faith do not face any disadvantage as a result of their report.

c) Awareness / Responsibility with Regard to Quality, Environment, and Safety

Every employee should be aware of the responsibility, impact, and significance of their personal actions with regard to:

  • the quality of our products and services
  • their impact on the environment and nature
  • their own safety and the safety of others, as well as
  • their impact on colleagues and business partners.

The Horn & Co. Group is committed to the responsible use of the environment and natural resources, also in line with sustainable corporate management. Every employee is expected to be aware of their responsibility regarding sustainability and resource conservation. Beyond legal requirements, we strive to continuously reduce negative environmental impacts wherever they can be influenced by the company.

d) Promotion of Charitable Activities

The Horn & Co. Group supports charitable activities both directly and indirectly through the active encouragement and involvement of its employees.

e) No Political Donations

The Horn & Co. Group does not make political donations or provide any form of contributions to political organizations. Should any donation or similar contribution be considered, prior approval must be obtained in accordance with internal company regulations.

4. Customers and Business Partners

We conduct our business with customers and stakeholders in an honest and fair manner and are committed to fair competition. Corruption is not tolerated in any form. Our guiding principle: customer focus.

a) Safety of Products and Services

Within the scope of our business activities, we comply with all legal requirements regarding product safety. We proactively provide information about our products and services, prevent product-related incidents in advance, and maintain and strengthen the trust of our customers.

b) Honest and Fair Business Practices

We engage in honest and free competition to earn the trust of our customers, business partners, and society, and we refrain from any actions that violate competition or antitrust laws in the various countries and regions in which we operate.

In particular, we do not engage in anti-competitive price or condition agreements, attempts to divide markets, bid rigging, or calls for boycotts.

In the course of our business activities, we ensure compliance with all relevant competition laws and regulations.

If we become aware of contractual terms or business practices that restrict fair competition, or suspect that such a situation may exist, we consult with a supervisor and act appropriately.

c) Hospitality and Exchange of Gifts

We do not offer monetary gifts to business partners or their executives in order to obtain preferential treatment within business relationships.

When hosting guests or exchanging gifts, we do so within an appropriate scope, in line with prevailing social standards and in compliance with the internal regulations of the respective companies regarding hospitality, gifts, benefits, and other economic advantages.

If accepting a gift is consistent with the customs and practices of a country and cannot be refused for cultural reasons, acceptance is permitted. The giver must be informed of this policy, and the respective supervisor must be notified of the situation.

The acceptance of money or other monetary benefits from third parties, such as loans, securities, or commissions, is strictly prohibited for all employees.

We do not accept hospitality or gifts that are intended or could be perceived as influencing the business decisions of the Horn & Co. Group.

d) Corruption

Any form of corruption, such as bribery or the granting or acceptance of undue advantages, is strictly prohibited, regardless of whether it occurs directly, through intermediaries, or involves private individuals or public officials. In particular, both the offering (active bribery, granting of advantages) and the acceptance (passive bribery, acceptance of advantages) of benefits intended to obtain an unlawful advantage are prohibited.

e) Import and Export

To avoid any situations or actions that could endanger international peace or security, we conduct the import and export of products, technologies, and services in full compliance with applicable laws and regulations, including foreign trade and currency control laws.

Governments and international bodies may impose trade restrictions or embargoes on certain products, countries, or individuals. Horn & Co. recognizes and adheres to these international regulations. We conduct our business activities exclusively in compliance with these rules and do not export goods or technologies subject to such restrictions.

All products we manufacture are designed for peaceful use. In exceptional cases, certain products may also be used for the production of goods for military purposes (so-called dual-use goods). In such cases, the relevant export control regulations must be strictly observed. In case of doubt, the competent authorities in the respective countries or the legal department should be consulted.

5. Employees

We expect respectful interaction, mutual respect, and a culture of open dialogue. Safety and occupational health are our top priorities.

Guiding principle: employee focus

a) Responsibility of Managers

We expect our managers to demonstrate leadership, determination, a sense of responsibility, openness to innovation, and to act as role models.

Our managers are responsible for ensuring that employees understand this Code of Conduct.

They are expected to create opportunities to discuss the Code with employees and communicate its importance. Managers must not issue instructions or make suggestions that would lead employees to act against social ethics, legal requirements, or internal company regulations—even if this would help achieve business objectives.

Our managers are also expected to foster an open working environment in which employees feel comfortable raising concerns related to the Code of Conduct.

They do not ignore compliance issues but instead ensure that appropriate corrective measures are taken promptly.

b) Respectful Interaction

We expect respectful interaction at all levels and actively promote this standard in relationships with customers and suppliers. The Horn & Co. Group is committed to equal opportunities, appreciation, trust, and performance. We provide our employees with a challenging work environment and encourage them to realize their full potential through ambitious goals.

We foster a culture of mutual trust, respect, and open dialogue. Every employee has the right to an individual performance evaluation.

We promote a culture in which people can develop their talents and ideas and are encouraged to achieve high performance. We support employee development, set ambitious goals, and reward strong performance.

We encourage responsible behavior from every employee and promote teamwork. All employees are expected to act to the best of their knowledge and in accordance with generally accepted ethical principles, and to raise concerns with their supervisors when necessary.

c) Occupational Health and Safety

For the Horn & Co. Group, workplace safety is the highest priority. Every accident is one too many. Every employee is encouraged to identify risks at their workplace and either eliminate them or report them to their supervisor.

All employees, contractors, and suppliers are required to comply with occupational safety regulations at our sites.

We are committed to promoting the health of our employees and encouraging a healthy lifestyle.

d) Respectful Handling of Company Property

The facilities in offices and operational sites are provided to support daily work and must be handled with care by all employees.

Employees are prohibited from misusing company property for personal purposes or from intentionally damaging or destroying it.

Certain company assets, such as laptops and mobile phones, may also be used for private purposes in accordance with company policies. The private use of mobile phones during working hours should be kept to a minimum. Separate regulations apply to the private use of company vehicles.

e) Information, Confidentiality, and Data Protection

All employees must securely handle confidential company information and only share it with colleagues to the extent necessary for achieving the respective business purpose. This applies equally to confidential information entrusted to us by third parties.

Confidential information includes, in particular, technical data relating to products or processes, marketing or sales strategies, internal pricing lists, customer data, non-public financial information, information on transactions, civil or criminal proceedings, and all personal data.

The Horn & Co. Group ensures the protection of employees’ personal data. In accordance with applicable data protection laws, personal data is processed only to the extent necessary within the employment relationship. Internal policies on information security and internet use apply.
To ensure compliance with GDPR requirements, all employees must handle information and IT systems with due care and responsibility. Careless handling may cause significant harm to the company, its employees, or third parties.

We respect and protect intellectual property and copyrights. This also applies to information belonging to customers, suppliers, and business partners. This protection must be observed and upheld in all areas of work.

f) Loyalty and Conflicts of Interest

We refrain from any actions where personal interests (including those of family members) conflict, or could potentially conflict, with the interests of the company.

If such conflicts arise or are suspected, employees must consult with their supervisor to seek guidance and act appropriately.

Contact

If you have any questions regarding the Code of Conduct or wish to report incidents confidentially, employees can contact their managers. In addition, the CSR Circle is available as a point of contact.

Email address: csrcircle@horn-co.de
Phone: +49 (0) 151 6443 35 91