0. Preamble
- Truffle Bay sees itself as part of an internationally integrated economy and, as a company based in
Munich, is part of the Federal Republic of Germany and its society. Truffle Bay follows the basic
understanding of the “honorable businessman” and acknowledges its responsibility: - Truffle Bay observes and takes into account the direct and indirect effects of its business activities
on the environment and society and endeavors to bring economic, ecological and social
concerns into an appropriate balance of interests - Truffle Bay acts in accordance with generally accepted values and principles, complies with
the law and, in particular, observes internationally recognized human rights and labor standards
as set out below. - Truffle Bay stands for the objectives and contents of the Code of Conduct and will make all
appropriate and reasonable efforts within the scope of its respective legal and actual possibilities
to comply with the voluntary commitment on an ongoing basis.
If existing national regulations contradict the contents of the Code of Conduct or the national context
makes it impossible to comply with them without restriction, Truffle Bay will look for ways to comply
with the requirements of the Code of Conduct as comprehensively as possible.
1. Truffle Bay management and all employees commit themselves to the CoC
- The management introduces the Code of Conduct as a binding set of rules for all employees
in addition to the legal and labor law framework. - All employees are informed and trained about the Code of Conduct. They are also made aware
that the Code of Conduct applies to all employees.
2. Ethical / moral commitment and integrity
- Truffle Bay will only pursue lawful business objectives and practices and will only do business
with reputable partners. - Truffle Bay behaves fairly and respectfully towards business partners and customers.
- Truffle Bay respects different legal, economic, social and cultural backgrounds and the special
circumstances of the countries and regions in which the company operates. - Truffle Bay respects the laws and regulations of the countries and regions in which it does
business. - Truffle Bay always bases its business activities on universal ethical values and principles, including
integrity and respect for human dignity. Truffle Bay is committed to free and fair global
trade.
3. Corruption, trade control, money laundering
- Truffle Bay rejects all forms of bribery and corruption. To this end, we avoid any appearance of
this - be it in the form of granting or accepting unfair advantages. - Truffle Bay acts in accordance with the applicable import and export control regulations and
complies with the legal requirements for the prevention of money laundering.
4. Fair competition
- Truffle Bay is committed to free and fair competition. Truffle Bay does not tolerate anticompetitive
agreements and ensures that the company always acts in accordance with applicable
antitrust laws. Truffle Bay rejects competitive advantages through unfair business practices.
5. Handling of personal data, protection of confidential information and intellectual property
- Truffle Bay respects the personal rights of its employees, business partners and customers and
complies with the applicable legal and regulatory requirements for the processing of personal
data and information security, in particular the GDPR, when handling personal information. - Truffle Bay protects entrusted trade secrets and other confidential information of its business
partners and customers from unauthorized acquisition, use and disclosure, at least in accordance
with the relevant legal provisions for the protection of trade secrets. - Truffle Bay respects the intellectual property of its business partners, customers and other
third parties and ensures that sufficient precautions are taken to protect intellectual property
rights when exchanging know-how and technologies.
6. Protection of consumer interests
- Insofar as Truffle Bay products and services affect the interests of consumers, suitable measures
are taken to ensure the safety and quality of the products or services. - Truffle Bay ensures that the products or services comply with the relevant statutory consumer
protection provisions. - In the context of information and sales measures, Truffle Bay takes consumer interests into
account by applying the legal requirements for fair business, marketing and advertising
practices and consumer education.
7. Environmental responsibility and commitment
- Truffle Bay always bases its business activities on universal ethical values and principles,
including integrity and respect for human dignity. - Truffle Bay is committed to free and fair global trade.
8. Protection of the environment and climate
- Truffle Bay assumes its ecological responsibility by applying the applicable legal requirements
and recognized standards for the protection of the environment and climate. - Truffle Bay works to continuously reduce the negative impact of its business activities on the
environment and climate.
9. Applicable legal provisions
- Truffle Bay applies applicable law and takes appropriate measures based on legal and internationally
recognized standards. - Truffle Bay is committed to the proper / professional and responsible handling of hazardous
substances, chemicals and waste, including their disposal. - Truffle Bay is committed to measures to reduce or avoid waste.
- Truffle Bay undertakes to minimize emissions from operational processes (e.g. waste water,
exhaust air, noise, greenhouse gases). - Truffle Bay is committed to the careful use of natural resources, for example through measures
to conserve water, chemicals and other raw materials and to promote the circular economy - Truffle Bay is committed to the use of climate and environmentally friendly technologies,
processes, raw materials and products. - Truffle Bay is committed to measures to increase energy efficiency and the share of renewable
energies in energy consumption.
10. Animal and species protection
- Truffle Bay observes the principles for the protection of animals and biodiversity and aligns its
business activities accordingly. The keeping and use of animals must comply with the applicable
legal animal welfare requirements and be species-appropriate. The Washington Convention
on International Trade in Endangered Species of Wild Fauna and Flora is the guiding
principle here.
11. Human rights and labor standards
- For Truffle Bay, human dignity is inviolable.
- Truffle Bay respects the internationally recognized human rights set out in the United Nations
Universal Declaration of Human Rights. - Truffle Bay adheres to the internationally recognized labor standards of the International
Labor Organization (ILO) as set forth in the Code of Conduct below. - In all business activities, Truffle Bay endeavors to neither cause nor contribute to human rights
abuses. Truffle Bay expects the same from its business partners. Where necessary and possible,
Truffle Bay also supports its suppliers in this respect.
12. Employment relationships
- Truffle Bay treats its employees with respect.
- Truffle Bay rejects any form of unlawful punishment, abuse, harassment, intimidation or other
unworthy treatment of employees. - Truffle Bay applies the applicable labor law to all employment relationships and expects the
same from its contractual partners. At the beginning of the employment relationship, employees
must be provided with comprehensible information about the essential working
conditions, including their rights and obligations, working hours, remuneration and payment
and accounting modalities. - Truffle Bay respects and protects the right of workers to terminate their employment with the
applicable notice period.
13. Rejection of child labor and protection of young workers
- Truffle Bay does not tolerate child labor and observes the applicable legal minimum age for
employment. - In any event, Truffle Bay will not employ anyone under the age at which compulsory education
ends under the law of the place of employment or under the age of 15. - Internships at Truffle Bay are organized in accordance with the statutory provisions.
- Truffle Bay expects its contractual partners to have appropriate means of determining age in
order to prevent child labor. - If child labor is detected, all necessary measures must be taken immediately to focus on the
welfare, protection and development of the child. - The rights of young workers under the age of 18 must be respected; they may only be employed
if it is ensured that the working and employment conditions neither pose a risk to their
health, safety or morale nor are detrimental to their development.
14. Rejection of forced labor
- Truffle Bay rejects forced or compulsory labor in any form.
- This also applies to any form of debt bondage, servitude, slavery or slave-like practices,
human trafficking and extends to all forms of involuntary labor and services that are incompatible
with internationally recognized labor and social standards.
15. Principles of remuneration
- Truffle Bay applies the statutory or - where applicable - collectively agreed provisions for the
remuneration of labor services. - Truffle Bay ensures that the payment of employees in the company does not fall below the
applicable statutory minimum wage or, if applicable, the minimum wage stipulated by collective
agreement or the minimum wage customary in the industry. - Wage deductions not permitted by law, including wage deductions as a disciplinary measure,
will not be tolerated by Truffle Bay.
16. Working hours
- Truffle Bay applies the statutory or applicable collectively agreed provisions on working
hours, including overtime, rest breaks and vacation. - Truffle Bay ensures that the regular weekly working hours plus maximum possible overtime
are not exceeded and that any working time regulations are complied with.
17. Diversity and inclusion, non-discrimination
- Truffle Bay values the diversity of its employees and promotes a working environment that
enables inclusion. - Therefore, Truffle Bay is committed to equal opportunities and rejects any form of discrimination
and unequal treatment based on national and ethnic origin, social background, health
status, disability, sexual orientation, age, gender, political opinion, religion or belief. - Truffle Bay lives by the principle of equal pay for male and female workers for work of equal
value.
18. Health and safety in the workplace
- Truffle Bay complies with national and international occupational health and safety standards.
- Truffle Bay provides a safe and healthy working environment (preventing accidents, injuries
and workrelated illnesses) to maintain the safety and health of its employees and third parties.
19. Measures in the event of a conflict of interest
- Disclosure: Employees must report all potential conflicts of interest immediately. This
concerns personal, financial or other relationships that could influence the objectivity or
independence of business decisions. - Assessment: Management will immediately review and assess the disclosed conflicts to
determine whether they could actually have an impact on business decisions. - Instructions for action: Based on the assessment, appropriate measures will be taken by
the management. In the event of employee misconduct, measures will be taken to remedy
the misconduct. Truffle Bay is guided by German labor law (depending on the case, a warning,
reprimand or dismissal) - Training and awareness-raising: Regular training and information events are held to sensitize
employees to the issue of conflicts of interest.
20. Introduction of the CoC
- Introduction: Truffle Bay did not previously have a Code of Conduct. The management has
decided to introduce the Code of Conduct with effect from 01. 11. 24. The extent to which the
CoC can become part of the employment contract will also being examined.
21. Violations of the Truffle Bay CoC
Truffle Truffle Bay provides for graduated sanctions for employees who violate the Code of Conduct.
a. Minor violations
- Verbal warning: This is Truffle Bay’s first action to point out the misconduct and clarify our
expectations. - Written warning: For repeated minor offenses, we will issue a written warning.
b. Moderate violations
- Formal written warning: This is the serious consequence that will be noted in the personnel
file and warn the employee. - Transfer or restrictions: If appropriate, the employee may be transferred to another position
or have certain responsibilities removed.
c. Significant violations
- Termination: For serious violations that jeopardize trust or safety in the workplace, termination
of employment may be the necessary consequence for Truffle Bay. - Legal action: In cases of serious misconduct, such as fraud or harassment, legal action may
also be taken by Truffle Bay against the employee
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