Entrepreneurial success requires a reliable and stable foundation. Clear rules are a basic requirement for ensuring that our actions are legally without flaw, morally sound and ethically exemplary. GROB upholds a zero-tolerance policy against unethical business practices of any kind. As a globally active family company, this is the standard we hold ourselves to.
What is generally defined by the term "Compliance" is active corporate culture at GROB: The core of our value-oriented company policies is to uphold the law. Our commitment to compliance includes not only nationally and internationally applicable laws and industry standards, but also the values and rules to which we have committed ourselves, as well as to our business partners. We are certain that only frameworks such as this will provide long-term security for our positions as an established market and technology leader, and live up to the trust placed in us by our customers, suppliers and the general public as a reliable and serious partner.
With our Compliance Management System, we intend to prevent violations of these principles, identify misconduct against these and put a stop to it with targeted measures. Our compliance organization is therefore not only an expression of our compliance culture, but it also an important protective function for GROB itself, its representatives and our employees – because compliance is something we all share! The following elements play a central role in this:
GROB management takes responsibility and leads by example:
"We are proud to be pioneers in manufacturing highly innovative production and automation systems, and wish to remain so. Nothing else applies to our corporate culture, which, in the tradition of a family business, has always been an expression of ethical and social responsibility. We desire to maintain this cornerstone of our success and ensure that it is robust enough to meet the challenges of the future. This is why we build on clear values, mutual respect and lawful action, especially in increasingly fast-moving times characterized by technological change and political uncertainties. For this, we undertake to work on ourselves permanently, shaping a sustainable environment together with our employees."
Christian Grob
GROB-WERKE Chairman of the Supervisory Board
We take responsibility, and set a high standard for ourselves.
Acting in accordance with the rules in our daily routine must be the norm for each of us. We have collected all vital and indispensable rules for conduct in a Code of Conduct (Compliance Guideline). This is valid across the entire Group. With this Code of Conduct, we express our self-image as a responsible employer and set binding guidelines that aids every individual in doing the right thing in our day-to-day work. As the heart of our value-oriented company culture, it is intended to convey respect as well as fair and responsible behavior in addition to the fundamental legal framework for economic and entrepreneurial activity. We wish to encourage all our employees to act as role models for legally impeccable behavior with ethical integrity in society and in the workplace. The GROB Group Code of Conduct is available in German, English, Portuguese, Chinese and Italian. A slightly different version applies for GROB USA and GROB Mexico.
We have this expectation not only of ourselves, however, but also of our business partners. With our Code of Conduct for business partners of the GROB Group, we address our suppliers specifically, who we expect to live up to their responsibility within the supply chain and to show commitment in promoting compliance with our principles among their own suppliers and subcontractors.
In addition, we specifically document our commitment to respecting internationally recognized human and environmental rights, our expectations of our employees and suppliers based on these rights and the processes we have put in place to implement our human rights and environmental due diligence obligations in the GROB Group's Human Rights Strategy Policy Statement. Our policy statement is available in German, English, Portuguese, Chinese, Italian and Indian.
We take responsibility and established a compliance organization that is responsible for the structure and continuous improvement of the Group-wide Compliance Management System.
From the GROB headquarters in Mindelheim, the Head of Compliance and his team control the GROB Group's worldwide compliance network. They ensure that our Compliance Management System is transported to all business areas and subsidiaries, and that comparable compliance standards apply everywhere.
For this, they communicate regularly both with the managers in Mindelheim and with the local Compliance Officers at the other GROB locations. The compliance team ensures that all relevant persons are involved in the development of compliance solutions. The Head of Compliance in turn maintains a close exchange with Management.
The compliance team is the direct contact for all compliance-related questions. It actively supports our employees in ensuring that they always behave in a legally impeccable manner and in accordance with the ethical rules of conduct in their day-to-day routines, but also in challenging situations. In addition, the compliance team regularly analyzes all business areas for potential compliance risks and reviews compliance with processes, procedures and standards. If necessary, appropriate measures for avoiding and minimizing risks are drawn up in consultation with the persons responsible for the processes. In addition, the compliance team establishes training concepts in line with requirements, and responds to information on possible irregularities and potential misconduct within the GROB Group.
We take responsibility and wish to reinforce the confidence of our employees to act.
With the help of guidelines and process instructions, we provide our employees with clear guidelines that often go beyond the legal requirements. Wherever the compliance team identifies potential compliance risks, we work with the relevant internal contacts to develop measures to avoid or minimize risks, and evaluate their effectiveness at regular intervals. For example, the handling of gifts and invitations is regulated separately.
There is also an internal set of rules for export control that ensures compliance with all legal requirements. Further special compliance guidelines and procedural instructions are currently being developed by the compliance team.
In our guidelines and procedural instructions, we rely on best practice standards by integrating release regulations, segregation of duties, job rotation, signature regulations and the dual control principle as fixed components of the individual process flows.
We take responsibility and act exclusively in compliance with the data protection laws relevant to us. This is a matter of special concern to us, as we regard behavior compliant with data protection throughout the company as essential to the success of our globally active company, and wish to provide the best possible protection for your data.
From Mindelheim, our Group Data Protection Officer and his team control the implementation of Group-wide legally compliant data protection within the GROB Group, and ensure the appropriate knowledge and support of every single employee worldwide through ongoing training and awareness-raising. Every employee identifies with data protection and takes responsibility for it. Data protection, that's something we all share!
The data protection team led by our Group Data Protection Officer is the direct contact for all our employees for data protection issues, and always actively supports our employees in data protection implementation, e.g., as part of specific projects, contracts or other plans. In addition, new processes in our business areas are regularly analyzed by our data protection team with regard to potential data protection risks, and established procedures are reviewed continuously to ensure they are up-to-date regarding implementation of data protection compliance. In consultation with the relevant process owner, appropriate measures for minimization and containment of risks are designed and implemented immediately in the event of any data protection compliance issues.
Our data protection team is also your point of contact for any issues you may notice in relation to the GROB Group's compliance with data protection. Only with your support can we eliminate any data protection issues occurring despite the greatest possible care on our part as quickly as possible. For this reason, please report any potential ideas for improvement that you might have. You can contact either the Chief Data Protection Officer and his team or the compliance team directly with your concerns, or use our Whistleblower System. We take your information very seriously and are particularly concerned with ensuring the best possible data protection compliance with your aid.
Silvia Seitz
Data Protection Coordinator
Sandra Forster
Group Data Protection Officer
We take responsibility and raise our employees' awareness of the need to deal with compliance-related issues in a risk-conscious manner.
The complexity and internationality of our business activities and our pursuit of perfection place high demands on each and every one of us. But only those who know the legal guidelines for their actions are able to detect potential compliance risks and take appropriate account of them in their day-to-day work.
We therefore attach great importance to promoting awareness among all our employees of possible compliance risks and the associated consequences for GROB itself, but also for its representatives and its employees, and to internalize these in the long term. It is important for us to provide our employees with the necessary knowledge to give them security in their daily work.
The training courses are created by the compliance team and, on the one hand, cover very basic compliance topics such as data protection, corruption and money laundering, which are mandatory for all employees; on the other hand, there are training courses which address specific compliance risks, for example from antitrust laws or export control, and are aimed primarily at employees from these departments.
We take responsibility and want to encourage all those involved – whether our employees or external parties – to report suspicions of possible wrongdoing, misconduct and irregularities within the GROB Group.
Transparency and openness are elementary values of our compliance culture. Only those who are aware of possible weaknesses in their organization can independently remedy occurring misconduct and optimize processes for the future. In the sense of an early warning system, it is important for us to be made aware of any misconduct as early as possible.
We are certain that a functioning whistleblowing system will sustainably strengthen the integrity of our Group and the trust of our employees, customers, suppliers, partners and other stakeholders, thus enabling us to remain a recognized business partner in the long term. At the same time, we are aware that despite conscientious prevention and the greatest prudence, (new) compliance risks and (unintentional) compliance violations can never be completely ruled out, and we are therefore dependent on information revealing such issues to us. We see every report as an important contribution to our ability to meet our compliance responsibilities.
Every interested whistleblower should therefore be able to address concerns as simply as possible. To this end, whistleblowers are free to contact the compliance team directly using the contact data below, or to submit their report via our digital whistleblowing system, which also allows anonymous reporting. The reporting platform is operated by the external service provider otris, for which the submitted tips are encrypted and cannot be traced to the compliance team in Mindelheim. This team processes the reports and initiates the necessary steps as quickly as possible.
Even after submitting a report, whistleblowers can use the encrypted chat function of the reporting platform to contact the compliance team and receive messages from the compliance team on the processing status or factual queries – anonymously, of course.
All information is treated confidentially and promptly. The protection of whistleblowers is a top priority for GROB. A person who has reported information in good faith is protected against any form of discrimination. This also applies if the report subsequently proves to be unfounded. However, deliberate abuse of the Whistleblower System will not be tolerated and may result in legal action being taken.
In view of the entry into force of the Supply Chain Due Diligence Act (German 'Lieferkettensorgfaltspflichtengesetz' or LkSG) on January 1, 2023, we expressly point out that reports on human rights and/or environmental risks and violations can also be submitted via the Whistleblower System. For details, please refer to the procedure rules (available in German, English, Portuguese, Chinese, Italian and Indian) provided for under Section 8 (2) of the LkSG.
Dr. Korbinian Feller
General Counsel
Head of Compliance
Dr. Monika Glogger
In-house Lawyer
Compliance Officer
Hannah Knebel
In-house Lawyer
+49 (8261) 996-0
GROB-WERKE GmbH & Co. KG
Industriestrasse 4
87719 Mindelheim
Germany
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