Dear employees and business partners,

As a commercial enterprise, NELE Kosmetik GmbH (hereinafter: NELE) has a duty to act lawfully and responsibly. As part of society, we regard this responsibility as a matter of course, which is why this Code of Conduct is intended to create a framework for respectful interaction and serve as a guideline. It applies both to conduct among employees and to relationships with business partners and stakeholders.
The conduct of each individual contributes to the trust of our customers and business partners, as well as to our reputation in society, and can be severely damaged by a single inappropriate act. The provisions contained herein are therefore binding for our employees; however, they do not replace any legal or official requirements, nor work instructions or process descriptions. We ask our business partners to follow these principles as well.

Human rights and employee well-being

Human dignity, personal rights and privacy are of fundamental importance to NELE and must be respected and upheld by all employees, business partners and stakeholders. To safeguard these, we rely on international human rights charters such as the European Convention for the Protection of Human Rights and Fundamental Freedoms.

We do not tolerate forced or child labour and reject any form of discrimination and unfair treatment – including bullying, insults and sexual harassment.

In addition, we uphold the rights of our employees and stand for fair working conditions, which is why we integrate occupational safety and health protection into our operational processes. We recognise the right to freedom of expression and tolerate political and trade union activities as well as charitable engagement by our employees as private individuals, provided these do not conflict with the principles of our Code of Conduct.

Our company is built on trust, integrity and respect. Every one of our employees is expected to put these values into practice in order to maintain a pleasant and respectful working atmosphere.

Compliance with laws

We are committed to strict compliance with the laws and regulations in the countries in which we conduct business. This applies regardless of any economic disadvantages and is a matter of course for our company. We expect the same from our business partners.

If there are discrepancies between national laws or relevant international regulations and our Code of Conduct, the stricter regulation shall apply in each case.

Violations of laws or of this Code of Conduct must be reported to the respective supervisor. If this is not possible due to special circumstances, any employee may also contact Quality Management or Mr Tillmann Hempel. If a criminal offence is observed, there is an obligation in any case to report it to the appropriate authority.

Data protection and confidentiality

We take the protection of personal data and confidential information very seriously and therefore protect it against unauthorised access and unauthorised inspection. Sensitive data is only passed on to third parties with the consent of the persons or institutions concerned. We always comply with the requirements of the statutory data protection regulation and other guidelines and requirements.

Comparable principles for handling sensitive and/or personal data also apply to intellectual property. The use of licensed, confidential or copyrighted information for personal or other benefits without the consent of the entitled parties is strictly prohibited. In addition, the use of insider knowledge, both privately and for business purposes, is prohibited by law.

Conduct in the competitive environment

NELE is committed to fair competition in the market in compliance with and observance of all (inter)national regulations. Unlawful exchange of information, price fixing or cartel formation with competitors and/or suppliers will not be tolerated. Espionage, theft and other illegal methods of obtaining information are also prohibited.

To avoid conflicts of interest, every employee is required to separate business and private interests and to make decisions based on factual and objective information. If potential conflicts arise, every employee is required to inform their supervisor. The further procedure must be documented.

Benefits in kind, gifts and bribery

To improve business relationships, NELE generally permits the exchange of appropriate gratuities. This includes hospitality or low-value giveaways linked to business activities. Applicable laws and international regulations must be complied with.

However, participation in corruption and other benefits in kind arising from (in)direct payments will not be tolerated under any circumstances. The acceptance of cash is therefore not permitted. Any violation will result in consequences under labour law.

Customer orientation

Our highest goal is customer satisfaction. We strive to make fair offers at all times and to respond positively to customer enquiries at all times. Our quality management is therefore an integral part of our operational processes. If, despite the safety measures taken with regard to quality, a complaint arises, we endeavour to find an appropriate and satisfactory solution as quickly as possible.

Smoking ban, alcohol consumption and intoxicants

There is an absolute smoking ban throughout the entire NELE building. This also includes the use of e-cigarettes. In addition to the premises, this also includes the outdoor area of the warehouse and the loading ramp. A designated smoking area for employees is located in front of the main entrance and may only be used during breaks or outside working hours.

There is an absolute ban on alcohol on the entire company premises. Performing any work under the influence of alcohol is strictly prohibited. Violations of this ban may result in consequences under labour law.
Alcohol consumption in small amounts is only permitted on special occasions, such as milestone birthdays, anniversaries or a colleague’s retirement, and only with the consent of the Managing Director, Mr Tillmann Hempel.

The consumption of other intoxicants in accordance with the German Narcotics Act (BtMG), such as illegal substances or the misuse of prescription medication, is strictly prohibited during working hours and may, if disregarded, lead to consequences under labour law, in extreme cases even dismissal. Violations of legal provisions may also result in criminal consequences imposed by the authorities.

Protection of company property and assets

All employees and business partners are obliged to handle NELE’s assets responsibly and with care. In addition, company property must be protected against loss, misuse, theft and access by third parties. This includes not only tangible items such as the building, machines, tools or office supplies, but also intangible assets such as electronic data, know-how and working time.