The compliance program of the Pruss Armaturen AG aims to ensure compliance with all legal provisions as well as internal company guidelines. It sets standards that must be met by the company’s management and that go beyond the legal requirements.
This comprehensive program places increased demands on company management that go well beyond general legislation. It is intended to ensure continuous monitoring and compliance with legal, ethical and internal company standards in order to promote responsible, sustainable and ethical business operations.
We are aware of our social responsibility and the obligation to uphold human rights. In the conduct of our business activities, we always put these principles at the forefront and ensure strict compliance with human rights within our company. We expect this commitment from our business partners as well.
Our Code is based on the corporate principles that apply to all employees. The basis of our actions, both within the Pruss Armaturen AG and in relation to customers, suppliers and other business partners and stakeholders, is compliance with rules and the practice of ethical conduct. We are particularly committed to fair business relationships based on trust.
In order to ensure your anonymity, we have commissioned an external law firm to anonymize the reports. We receive your complaints without any contact details. The law firm is an independent legal law firm.
You can use the reporting system to report violations of our Code of Conduct or violations of the law. Including issues related to bribery and corruption, competition law, fraud, financial crime, product safety and quality, harassment or discrimination, international trade controls, the protection of personal data, rights and protection of persons, serious environmental damage or conflicts of interest.
In order to be able to handle your complaint as precisely as possible, we would like to ask you to include the following information in your email:
The Pruss Armaturen AG, hereinafter referred to as the “Company” or “PRUSS”.
At PRUSS, integrity and compliance with laws and internal regulations are our top priorities. In order to ensure compliance with these values and to avoid or minimise possible risks from violations, it is crucial that misconduct is detected, clarified and remedied at an early stage. Any indication of possible misconduct will be taken seriously and will lead to an investigation according to an objective and transparent procedure without any bias.
Violations of laws and internal regulations carry the risk of significant damage to the company, the management, every responsible manager and every affected employee. In addition to high fines, which can also affect PRUSS as a company, the persons involved are threatened with external personal consequences, which can include fines or, depending on the case, imprisonment, as well as internal personal consequences. In addition, compliance cases can lead to reputational and economic damage (e.g. negative media coverage, loss of revenue), claims for damages (e.g. from customers) and exclusion from public tenders (“blacklisting”).
The management is legally obliged to investigate any suspicion of illegal or inappropriate behavior of which it becomes aware on its own initiative. Compliance violations and violations of the law found in the process must be remedied immediately and sanctions must be considered. In addition, the management is obliged to check whether civil law claims for damages can be asserted against the offender. In order to comply with the legal obligations, the management of PRUSS has set up a whistleblower platform and established a process for clarifying incoming information.
The presentation and explanation of whistleblowing at PRUSS on the basis of this document takes into account various legal requirements for whistleblower systems and whistleblower protection, such as the EU Whistleblower Directive 2019/1937, corresponding implementation laws, the Act on Corporate Due Diligence in Supply Chains (LkSG), etc. Information from whistleblowers helps CTRINA to counteract violations at an early stage and to reduce the damage to our company, our employees and our business partners.
Who can inform about a violation?
All PRUSS employees, customers, suppliers and other third parties (e.g. directly affected, persons with knowledge of a (possible) violation by a direct/indirect supplier) have the opportunity to contact us via various channels to report violations.
What can be reported?
Violations of internal regulations and/or applicable laws can be reported through multiple channels. Indications or suspicions of violations can also be reported and are taken seriously. Therefore, the term “violations” in this document refers to both actual and potential violations within the meaning of § 2 HinSchG. The following behaviors/facts come into consideration, for example:
Notifiable behaviors are not exclusively personal, work-related complaints. A personal, work-related complaint is a complaint about a matter related to an employee’s current or past employment that has or may have a personal impact on the person in question, but which does not have a wider impact on the company. Examples of personal, work-related complaints include:
Personal, work-related complaints should be reported to the responsible manager, the HR department or the works council.
Who is responsible for the whistleblower system?
The Human Resources department is responsible for the management of PRUSS’s whistleblower system. The persons entrusted with the management of the whistleblower system ensure impartiality, are independent, are not subject to instructions and are obliged to maintain confidentiality. Indications of possible violations are processed by a PRUSS case handler.
Indications of violations of global minimum labour standards to which PRUSS has committed itself can be reported to PRUSS. In addition to the recognition of the ILO core labour standards and the recognition of the Universal Declaration of Human Rights, these minimum labour standards include principles of good occupational health and safety, opportunities for professional and personal development, the right to appropriate remuneration, the prohibition of child and forced labour and the prohibition of discrimination of any kind.
Anonymity and confidentiality
The anonymity of whistleblowers in reporting is permissible (as far as legally possible). Information disclosed in the course of an investigation will be kept confidential to the extent possible and appropriate.
Protection of whistleblowers (no retaliation)
PRUSS prohibits and does not tolerate any kind of retaliation (e.g., adverse actions, disciplinary measures, threats, intimidation) for reporting a violation in good faith or otherwise cooperating in the investigation of a violation. Any violation should be reported through one of the reporting channels provided by PRUSS in order to ensure that management is aware of it and thus provides adequate protection for whistleblowers. Reporting knowingly false information (“malicious report”) is itself a violation, and actions taken as a result of such malicious reporting do not constitute retaliation.
Other Data Subjects
In its investigations, PRUSS strives to protect the legitimate interests of other persons affected by a disclosure. Bringing another person under suspicion can have serious consequences. In its investigations, PRUSS strictly adheres to the principles of the “presumption of innocence” and the “need to know” principle. It is important that the whistleblower system is used responsibly. PRUSS will not support actions that could make employees victims of unfounded or false accusations.
Examinations are carried out in accordance with the following principles:
1) Basic principle
We investigate any indications of compliance violations or risks through internal investigations based on transparent and clearly defined processes. In this way, we ensure that our internal standards are consistently implemented and that our management and executives live up to their legal and corporate responsibility.
2) Compliance with legal requirements
Our investigations are always carried out in accordance with all applicable laws and regulations.
3) Right to be heard
No one has to worry about facing consequences from an investigation until they have had the opportunity to comment on the allegations.
4) Strict “need to know” principle
Only people who are actually needed for an examination are involved in our activities. The information on the results of the investigation will only be made available to those parties who actively need it for further proceedings or to comply with legal obligations.
5) Confidentiality
All information collected in the course of compliance investigations will be treated confidentially. The identity of the whistleblower is protected with the utmost care.
6) Fairness and mutual respect
The investigations will be conducted fairly and with respect for all parties concerned, following an objective and transparent process without any bias. The “presumption of innocence” applies to all internal investigations. Any kind of coercion, threat or the like is not permitted. The investigation activities are carried out without undue delay, in order of priority and urgency, and taking into account costs and effort.
7) Usability of the results
Compliance investigations are conducted in such a way that the results can generally be used in court
When conducting internal investigations, PRUSS ensures that the requirements of the applicable data protection laws are complied with. If you would like specific information or have questions about the processing of your personal data, you can contact PRUSS’s Data Protection Officer using the contact details below:
Data Protection Officer: Phillip Hess
CERTINA Holding AG
Robert-Koch-Str. 5a
D-82031 Grünwald
Tel: +49 (0) 34946694400
E-Mail: phillip.hess@certina-group.com