Code of Conduct

A. Preamble

The Papier- und Kartonfabrik Varel (hereinafter referred to as PKV) is committed to social responsibility and responsible corporate management. This Code of Conduct describes the principles that PKV considers to be essential for responsible corporate management. In general, all our actions in all areas, in particular towards customers, suppliers, business partners and our employees, should be guided by the principles of integrity and fairness. Sustainability and the protection of our environment are essential principles that guide all our actions.
The provisions of this Code of Conduct reflect the fundamental attitude of PKV. However, they do not establish any enforceable legal claims against PKV.

B. General principles

  1. Compliance with laws
    In all countries in which we operate, we comply with all applicable laws, standards and other legal provisions and also observe the existing social rules.
  2. Businesspartners and authorities
    PKV is committed to the principle of fair competition towards all market participants and competitors and works exclusively in accordance with generally accepted business practices with special consideration given to fairness and honesty. We maintain a relationship of trust and partnership with the authorities.
  3. Business secrets
    All employees of PKV are obliged to maintain secrecy about all business matters. This obligation shall continue to apply even after termination of the employment relationship. Business secrets of third parties are also treated with the necessary confidentiality by PKV and its employees.
  4. Environmental protection and sustainabilitv
    Environmentally friendly and sustainable products and production processes are both a concern and an obligation for us. It is one of our major endeavours to bring ecology and economy into harmony. This is an elementary component of our corporate policy and corresponds to our responsibility for the region and the people living here. In order to meet our demand for environmentally friendly and sustainable paper and cardboard production, our production processes are continuously optimised from the point of view of ecology. We are certified in the areas of environmental, quality, energy and hygiene management in accordance with ISO 14001, 9001, 50001 and HACCP/EN 15593.

C. Ethical, global and social principles

  1. Human rights
    We commit ourselves unconditionally and irrevocably to always respect and guarantee human rights as the highest good in all our actions. We strictly reject forced labor in any form. We expressly reject any form of child labour.
  2. Discrimination
    We firmly reject any form of discrimination. This applies in particular, but not exclusively, to discrimination and disadvantages based on ethnic origin, gender, religion or ideology, disability, age or sexual orientation. We fully comply with the provisions of the “Allgemeines Gleichbehandlungsgesetz” (German General Equal Treatment Act).
  3. Occupational safety and health protection
    Occupational safety and health protection are very important goods for us, which always have priority over the goals of production. All applicable regulations in this area must be strictly observed, conditions must be created that avoid risks to health and safety. In this connection, the regulations of the Labour Protection Act and the Working Hours Act must also be strictly observed.
  4. Remuneration
    PKV guarantees that the remuneration of its employees fully complies with the applicable laws, in particular the Minimum Wage Act as the minimum standard. In addition, the collectively agreed regulations on remuneration issues are fully guaranteed and complied with.

D. Principles of competition law

  1. Antitrust and competition law
    We commit ourselves unreservedlty to exclusively fair competition with our market competitors. We comply with all applicable antitrust and competition laws. We reject price and condition agreements as well as agreements that serve to restrict competition or divide markets and customers.
  2. Bribery and corruption
    All forms of bribery and corruption are strictly rejected, and corresponding behaviour is not tolerated by PKV under any circumstances.
  3. Acceptance of gifts
    PKV employees may not offer, grant or accept any improper advantages to business partners within the scope of their business activities. The acceptance of gifts is prohibited. The only exceptions are hospitality in accordance with normal practice or occasional gifts of low value. The acceptance of monetary gifts is absolutely prohibited in any case and in any amount. Without exception, a strict standard must be applied here.

E. Implementation

  1. Employees
    PKV brings this Code of Conduct to the attention of its employees in an appropriate manner and at regular intervals and ensures compliance with the regulations laid down here.
  2. Business partners
    We also expect our business partners to comply with all applicable laws and regulations in their cooperation with PKV. We recommend our business partners to introduce similar principles.

Management of Papier- und Kartonfabrik Varel GmbH & Co. KG