Business-Ethics &
Supply Chain
Compliance with legal regulations and fair dealings with all stakeholders throughout the entire supply chain are integral parts of corporate policy.
COMPLIANCE AND SUSTAINABLE SUPPLY CHAIN
Rosenbauer delivers the majority of its products to public institutions and authorities. This results in increased responsibility that is particularly characterized by efforts to avoid corruption and bribery. The applicable laws and guidelines, as well as self-imposed standards, form the statutory framework here. These apply equally to in-house employees and external sales partners who are in contact with officials and state or local authority representatives.
Moreover, Rosenbauer is convinced that economic success can endure only if it is achieved in compliance with all the applicable laws, regulations and rules of fair competition. At the same time, it is committed to more than just statutory provisions. Internal regulations, voluntary obligations and ethical standards are of equal significance.
Rosenbauer Code of Conduct
The Code of Conduct governs the internal ethical guidelines for doing business. Its cornerstones are compliance with the law, fair competition, and the rejection of corruption and bribery. All rules governing international trade and the capital market must always be complied with and conflicts of interest avoided. Furthermore, Rosenbauer’s intellectual property, material assets and employees’ and customers’ personal data must be protected at all times, and people and the environment protected from danger. The Code of Conduct is applicable to all of the Group’s employees and sales partners worldwide.
RESPONSIBILITY – TRUST – RESPECT
1 We abide by the law and act in accordance with fundamental ethical principles.
2 We stand up for free and fair competition.
3 We reject corruption and bribery.
4 We avoid conflicts of interest.
5 We treat each other with respect.
6 We protect the company’s intellectual property.
7 We view sustainability as a constant companion.
8 We comply with capital market regulations.
COMPLIANCE
To ensure lawful and ethically sound conduct, Rosenbauer established a compliance organization in the company, which supports management in fulfilling this responsibility and is subject to continuous improvements. The compliance organization includes a reporting system for suspected compliance infringements. A central component is the company’s own Code of Conduct, which is not only binding for all employees of the Group, but also for suppliers and sales partners (see p. 19). Since 2021, there has also been a separate Code of Conduct for suppliers, the Supplier Code of Conduct.
In order to raise and maintain awareness of the relevance of compliance in the course of day-to-day business operations among employees and sales partners, the following measures were established and have been constantly expanded and improved since compliance management was introduced:
- conducting mandatory training for all compliance-relevant employees,
- business partner due diligence before signing every cooperation agreement, and expanded and continuous vetting of existing partners to ensure that the audit results are up to date and valid.
The success of these measures is monitored based on the number of trained employees, and potential and existing partners vetted.
Compliance-Organisation
It goes without saying that Rosenbauer complies with all legal provisions to combat corruption and with anti-trust and competition law. Illegal conduct and behavior that could negatively impact on the company’s reputation are not tolerated. The Group Compliance Officer reports directly to the Executive Board and provides the Supervisory Board with information on compliance activities and any relevant incidents at least once a year.
To enable any misconduct to be flagged and pursued, the company introduced its own whistle-blower system in 2014. It can be used by employees and outsiders to the company alike – anonymously, if they wish. In December 2021, the existing whistleblower system was expanded to include a new web-based tool, the “Integrity Line,” which offers an additional reporting option for whistleblowers in line with the requirements of the European Union. Violations of the Rosenbauer Code of Conduct or breaches of the law can be reported confidentially and completely anonymously. There are disciplinary consequences in place, depending on the severity of proven infringements; these range from a warning to immediate dismissal. In 2021, no compliance violation reports were submitted to Group Compliance. Two sales partners were excluded from doing business with Rosenbauer based on compliance-relevant information in 2021. These were one existing and one potential partner.
Compliance training for employees
All employees and sales partners are handed the Code of Conduct when they start working with us. They have to sign it. Employees in positions relevant to compliance receive regular training as needed. These courses are also available throughout the Group on the company’s intranet. This ensures that the information is available to all employees for reference purposes at all times, not just during courses. In spring 2020, an online anti-corruption and anti-trust course was established which is available throughout the Group and can also be made available to sales partners. Course participants can successfully complete the training by passing a test, after which they receive a certificate. Since the start of online learning, over 500 employees (particularly executives) have successfully completed both training courses.
Number of Rosenbauer employees who participated in compliance training in 2021 (excluding e-learning)
Combating bribery and corruption
The main task and feature of Rosenbauer’s compliance organization is the continuous effort to ensure the correct and lawful action of all parties involved. With the goal of preventing corruption in the first place, the focus is on identifying risks early on and taking suitable action to eliminate them.
Rosenbauer has been certified in accordance with ISO-37001 “Anti-bribery management systems” since 2021. This first-time certification underscores Rosenbauer’s innovative leadership in this area. Certification brings considerable advantages in terms of legal certainty and can also provide a decisive competitive advantage in tendering procedures. The certified compliance management system enables Rosenbauer to demonstrate compliance with its corporate due diligence. The first monitoring audit is planned for May 2022, which will include the whistleblower system announced in December 2021.
All sales partners are subject to a specific risk-oriented integrity review to identify potential corruption risks. This is done webbased using an online tool specializing in integrity checking. Potential new partners are subject to reviews before the start of collaboration, while existing partners are checked at regular intervals. In addition, the compliance organization carries out a case-specific plausibility checks of individual sales projects. Along with Internal Audit, on-site check or audits are conducted at sales partners with heightened risk. A total of 124 business partners were assessed as part of our integrity reviews; a total of two were rejected as a result. There were no known cases of corruption in 2021.
Respect for human rights
As an international company operating in countries with very different human rights situations, respect for human rights is a matter of particular importance to Rosenbauer. Treating employees and all partners with fairness and appreciation is a core element of our corporate culture. Rosenbauer is committed to not discriminating against anyone due to ethnic origin, skin color, religion, gender, sexual orientation, or any other traits. The principles of the Charter of the United Nations and the European Convention for the Protection of Human Rights and Fundamental Freedoms are respected and regarded as fundamental values.
Regardless of the location in the various countries, Rosenbauer takes particular care to treat its employees fairly. For example, at the production facilities in King Abdullah Economic City (KAEC, Saudi Arabia) care is therefore taken to ensure that every employee is in fact able to take annual leave. This is particularly important for migrant workers, who are otherwise able to travel to their home country only every two years. Treating different hierarchies, religions and nationalities with respect is also a matter of course at this location and all other locations.
TAX TRANSPARENCY
As an internationally active Group, Rosenbauer strictly adheres to the laws and regulations of those countries in which it operates, and cooperative and transparent collaboration with the tax authorities is also a matter of course. Tax-related issues are also incorporated into the global internal control system and the global risk management system. A whistleblower system in the form of the Integrity Line is available for reporting unethical and illegal behavior. No direct political influence is exerted on tax issues.
Sustainable tax strategy – tax follows business
Rosenbauer’s tax strategy focuses on supporting its core business. This means that, first and foremost, transactions and processes are optimally aligned with the requirements of our customers and products. Measures to optimize tax expenses are therefore only implemented if they do not have a negative impact on business processes and internal corporate management.
Accordingly, value added is also reported in the country from which the actual value added of a transaction results. Groupwide compliance with the transfer pricing guideline achieves this goal and fulfills the requirements of the OECD Transfer Pricing Guideline.
Rosenbauer expressly rejects the use of aggressive tax planning. This means that atypical constructions to avoid tax payments (offshore companies, treaty shopping, etc.) are not used.
Tax compliance
Tax agendas are coordinated by the global tax department, while local tax compliance is the responsibility of the respective commercial directors of the areas or the commercial managers of the subsidiaries.
Internal tax training courses for employees, in particular for sales staff, are held several times a year. In the event of current changes in tax legislation, these are proactively prepared and communicated to the relevant departments by the Group tax department.
As part of the SAP S4/HANA rollout, tax compliance will be taken to a new level through the automatic generation of tax codes and another step will be taken in the digitalization of business processes.
Tax payments
For the breakdown of country-by-country reporting on income-related corporate taxes, see Sustainability Report p. 53f.
SUSTAINABILITY IN THE SUPPLY CHAIN
As a global enterprise, Rosenbauer leverages the opportunities afforded by global procurement while also meeting its social responsibilities. This includes complying with the applicable laws and respecting fundamental ethical values everywhere and at all times in addition to acting sustainably. In line with this strategy, Rosenbauer also expects responsible conduct from its suppliers and partners, and their employees. Close cooperation with all suppliers and partners is a critical factor for Rosenbauer’s success. They are selected according to strict criteria and regularly assessed. In general, business relationships with key suppliers to the major production facilities are longstanding. With production on three continents, Rosenbauer generates regional added value around the world. The goal of working with local suppliers and partners is to safeguard jobs in the regions concerned and to promote local economic development through wages, investment, purchases and taxes. Where core products for equipment – such as protective clothing and shoes – are concerned, Rosenbauer consciously works with manufacturers in Europe in order to better monitor quality and working conditions at the production facilities. All helmet production takes place in Austria.
The programs for promoting a sustainable supply chain at Rosenbauer include the following:
- inspections of the production facilities manufacturing the core
products for equipment - regular evaluations and supplier visits, and
- close cooperation and exchange of information among suppliers
and among purchasing departments throughout the Group.
Suppliers’ environmental management
Rosenbauer also includes its suppliers in its environmental management. In this regard, the focus is on reducing packaging material and waste, for example with reusable transport racks instead of disposable cardboard boxes.
Many of the environmental impacts of Rosenbauer’s business activities stem from the upstream supply chain processes, such as the mining of raw materials and their processing in the metal and plastics industries. Consequently, Rosenbauer examined all its key suppliers for how they ensure environmental protection and embed this in their organizations. On the one hand, this insight into its suppliers’ manufacturing facilities provides Rosenbauer with an understanding of environmental impact in its supply chain and, on the other hand, initiates an awareness-raising process on this very topic.
Supplier screening
Rosenbauer has maintained close business relationships with some of its suppliers for decades. Key suppliers, i.e. those with a purchasing volume over € 100,000 in 2021, are screened regularly against environmental and social criteria to ensure that certain minimum standards are maintained. Rosenbauer aims to give sustainability even more weight when selecting new and managing existing suppliers. The company plans to automatically include sustainability-specific questions when adding new suppliers to the database system.
| Suppliers of Rosenbauer group with certificates | 2021 | 2020 | 2019 |
|---|---|---|---|
| Suppliers with Code of Conduct | 72.8 | 72 | 71.7 |
| Suppliers ISO 14001 | 59.6 | 59.2 | 58.9 |
| Suppliers ISO 14001 | 22.2 | 20.6 | 20.6 |
| Suppliers ISO 50001 | 7.7 | 7.1 | 7.0 |
| Suppliers ISO 45001 | 7.2 | 7 | 7.1 |
Avoidance of child and forced labor
Rosenbauer vehemently rejects child labor and forced labor. This is actively checked among key suppliers. None of these suppliers manufactures any products whose manufacture involves an above average risk of child labor or forced labor. To guarantee respect for human rights, all suppliers with a procurement volume of over € 100,000 are asked to submit a declaration on the avoidance of child labor and forced labor. In this declaration, business partners recognize human rights and confirm that no child labor according to the definition of the ILO Convention is involved in the manufacture of their products, and that people do not work against their will. Of the suppliers surveyed, 71% signed the declaration, or subscribe to even higher human rights standards, such as those of the UN Global Compact.
Percentage of suppliers who signed a declaration on the avoidance of child labor and forced labor
DATA PROTECTION
In the course of the introduction of the EU General Data Protection Regulation, Rosenbauer worked more intensively on the topic of data protection and implemented processes to guarantee their realization. An in-house coordinator was appointed for data protection, coordinating information on all processes relevant to data protection, including the necessary security precautions and types of data involved. In 2021, there were no substantiated complaints concerning data protection violations of customer or employee privacy, or the loss of personal data, for example.
The outbreak of the COVID-19 pandemic did not necessitate stricter security measures at Rosenbauer for the purpose of data protection. The company has been working on putting in place a robust and scalable IT system to ensure performance and security for years now. In the coming year, Rosenbauer plans to introduce a Data Protection Management Forum comprising Executive Board representatives, the Data Protection Coordinator, the Group Compliance Officer, the Head of Human Resources, and other members as required. The forum is tasked with maintaining, monitoring and continually improving the data protection management process in the organization.