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© 2020 Georgiou-Botaris Automobile Couture

Georgiou-Botaris Group company

CODE OF CONDUCT

Foreword by the Board of Management

 

Dear colleagues,

 

The trust of customers and stakeholders in our Company and its luxury services is our most precious asset. It therefore follows that we have a shared responsibility to live up to this trust every day by conducting ourselves with honesty and integrity. That includes being familiar with the applicable internal rules and statutory regulations and complying with them. It offers guidance on proper conduct by providing orientation and support in our daily work. It is precisely in times like these, when the automotive industry is undergoing fundamental change, that a solid foundation of values is indispensable for sustained success. Our Company is very diverse – with today being a part of 3 companies serving worldwide markets and with customers in over 150 countries are all part of Georgiou-Botaris Group’s world. Irrespective of the differences between us, our origins, our tasks, our responsibilities, it is shared values that determine how we go about our duties, how we make decisions and how we interact with one another and with people from outside our Company. Regardless of our position in the Company, we all share responsibility for the reputation, and thus the success, of our Company through our attitude and our conduct. If we notice that something is going wrong, if we make a mistake ourselves or we see a mistake being made elsewhere, we must speak up and respond appropriately – even if doing so is awkward and uncomfortable. Turning a blind eye can never be the right solution. When in doubt, we must seek competent advice and support. We, the Board of Management of Georgiou-Botaris Automobile Couture, are convinced that our Code of Conduct is an essential key to making Georgiou-Botaris Group and its brands even more successful in the future. The clear and transparent rules and very specific practical examples are a useful guide. We therefore encourage you to read the contents carefully. And we hope you will join us in working together to make Georgiou-Botaris Group a byword not only for excellent products and services, but also increasingly for integrity and fairness.

Our responsibility for compliance

 

One decisive factor for the success of our Company is that all employees – from Board members and managers to each individual member of staff – must act with honesty and integrity and in an ethical manner. This also means that our internal and external reporting and communications must be truthful, comprehensive and timely. Our shared goal is to fulfill our responsibility to our Company and to protect the reputation of our Group brands. Sustainability requires of us an awareness of our responsibility for the economic, social and ecological impact of our actions. Such conduct also means that we all respect and observe the rules in force in the Company everywhere and at all times. Our Board members and managers bear a special responsibility in this context: they are role models and must prevent non-compliant behavior within the Company, protect their employees and conduct themselves with integrity both within the Company and externally. This Code of Conduct helps us by highlighting potential areas of risk and conflict, explaining their significance for our Company and illustrating them using examples. The information contained in this Code of Conduct is divided into three main sections: • Our responsibility as a member of society • Our responsibility as a business partner • Our responsibility in the workplace. The Code of Conduct serves as a binding guideline in our day-to-day business. It is supplemented by internal guidelines and provisions in employment contracts. It also goes without saying that we all comply with the national and international statutory provisions. This also means that we never take any part in any activity that involves fraud, misappropriation, extortion, theft, embezzlement or any other deliberate damage to the assets of our customers or any third party. Failure to observe the Code of Conduct can result in considerable damage, not only to our Company, but also to us as employees and to our business partners and other stakeholders. That is why the Code of Conduct is binding on all of us, irrespective of whether our role is that of a staff member, a manager or a Board member. We do not tolerate violations of the Code of Conduct. Anyone who violates the Code of Conduct must expect consequences, which, depending on the seriousness of the violation, can range from action under labor law to claims for damages under civil law, and may even extend to penalties under criminal law. To make sure that does not happen, it is up to each and every one of us to familiarise ourselves with this Code of Conduct, to integrate the Code of Conduct into our own behavior, and to bear the Code of Conduct in mind when making decisions. When in doubt, we seek competent advice.

Our responsibility as a member of society

 

Our social responsibility means that observing and complying with the law is a matter of course. We have a duty to observe the law under which we operate in all business decisions we make. Every employee of Georgiou-Botaris Automobile Couture must be aware of his/her social responsibility, particularly as regards the well-being of people and the environment, and ensure that our Company contributes to sustainable development. Georgiou-Botaris Group’s responsibility as a member of society specifically gives rise to the following principles:

Human rights

 

Background

 

The Declaration of Human Rights adopted by the United Nations and the European Convention for the Protection of Human Rights and Fundamental Freedoms state what is required and expected of the international community when it comes to observing and respecting human rights.

 

Corporate principle

 

We respect, protect and promote all regulations in force to protect human rights and children’s rights (hereinafter called human rights) as a fundamental and general requirement throughout the world. We reject all use of child labor and forced or compulsory labor as well as all forms of modern slavery and human trafficking. This applies not only to cooperation within our Company but also as a matter of course to the conduct of and toward business partners.

 

My contribution

As an employee, I can also make my contribution to respecting human rights. I regard human rights as a fundamental guideline and I am vigilant against human rights abuse happening around me. If I have concerns regarding human rights abuse in my professional surroundings, I prevent it and/or stop it. If necessary, I inform my superior.

Example

You are responsible for purchasing specific goods. You receive information that a supplier with which you do business uses children in their production process, or that employees are made to work in inhumane conditions (e.g. exposed to health risks). Take the necessary steps and inform your superior and the units responsible for sustainability in supplier relations. Our Company must examine business relations with this business partner more closely and, if necessary, break them off.

Equal opportunity and equal treatment

 

Background

 

Equal opportunities and equal treatment are key cornerstones of a fair, unprejudiced and open approach. Georgiou-Botaris Automobile Couture encourages respectful cooperation in a spirit of partnership, diversity and tolerance. That is how we achieve a maximum degree of productivity, competitive and innovative capability, creativity and efficiency.

Corporate principle

We offer equal opportunities for everyone. We do not discriminate or tolerate discrimination on grounds of ethnic or national origin, sex, religion, views, age, disability, sexual orientation, skin color, political views, social background or any other characteristics protected by law. We embrace diversity, actively encourage inclusion and create an environment that fosters each employee’s individuality in the interests of the Company. As a matter of principle, our employees are chosen, hired and supported based on their qualifications and skills.

My contribution

I observe the principles of equal opportunity and equal treatment and encourage people around me to do the same. If I see any contravention of the principles of equal opportunity and equal treatment (disadvantagement, harassment or mobbing), I make the persons involved aware of their misconduct. If I am not in a position to influence the events directly, I notify the human resources department of the incident.

Example

You find out from a colleague who is a friend of yours that an applicant in his department was rejected because of the color of his skin, although he was the best candidate for the advertised job. Help clarify the situation by reporting the case to the relevant human resources department so that appropriate steps can be taken.

Product conformity and product safety

 

Background

 

Countless people come into contact with our products and services on a daily basis. Georgiou-Botaris Automobile Couture bears a responsibility for preventing, to the extent possible, any risks, detrimental effects and hazards to the health, safety, environment and assets of our customers or any third party arising from the handling and use of these products and services.

 

Corporate principle

 

For that reason, it is not only our statutory duty but also our mission to comply with the laws and regulations as well as the internal standards that apply to our products. Our products are state of the art and are developed in accordance with legal requirements. This is monitored continually and systematically through processes and structures, as well as through product surveillance under real field conditions. We make no compromises on that. We ensure that suitable measures can be taken in good time in the event of any discrepancies.

 

My contribution

 

If I notice or have concerns that our products could present a threat or that regulations are not being observed, I take counteraction. I report the matter to my superior and to the relevant contacts in the Company.

 

Example

 

A customer reports technical problems with a vehicle to you. You are not sure whether or not they are due to a mistake on the customer’s part when operating the product, and you cannot definitively rule out a manufacturing or construction defect. Clarify the matter. It is essential to ensure that our Company will solve a problem for which it is responsible. Even customer mistakes when operating the product may require the Company to respond (e.g. by modifying operating instructions or user training).

Environmental protection

 

Background

 

Georgiou-Botaris Automobile Couture develops, produces and distributes vehicles, services and mobility solutions worldwide. Our Company’s mission is to be a global provider of sustainable and individual mobility. In pursuing this mission, the Company is aware of its special responsibility toward the environment.

 

Corporate principle

 

As a commercial enterprise, we bear responsibility for the environmental compatibility and sustainability of our products, locations and services. We focus on environmentally friendly, advanced and efficient technologies, which we implement throughout the entire lifecycle of our products. Starting with the early phases of development and production, we make sure we manage natural resources carefully and steadily reduce the environmental impact to comply with environmental protection laws and regulations. Furthermore, we constantly reassess the environmental compatibility of products and manufacturing processes, optimizing these where necessary. We are a responsible member of society and a partner for politics. We seek a dialog with these players on future mobility concepts and on shaping ecologically sustainable development.

 

My contribution

 

I bear environmental protection in mind in my work and use resources and energy economically and efficiently. I make sure my activities have the smallest possible impact on the environment and that they comply with applicable environmental protection laws and regulations.

 

Example

 

You notice that there is a leak in a tank and that significant amounts of chemicals are seeping into the ground. Immediately inform one of the employees responsible and draw attention to the problem. Do not rely on somebody else reporting the leak.

Communication and marketing

 

Background

 

Georgiou-Botaris Automobile Couture believes it is important to communicate clearly and openly with employees, business partners, shareholders, investors, the media and other stakeholders using honest and lawful means. All our employees bear a responsibility to observe internal communication rules to ensure that we present a unified and consistent image of the Group. All our employees recognize the achievements of those they engage with and respect their professional and personal reputation.

 

Corporate principle

 

We ensure that our communication is clear and consistent in order to maintain the confidence of customers, investors and other stakeholders. Before committing to and executing any planned communication or marketing measures, such measures must first be coordinated with the relevant department.

 

My contribution

 

I do not issue any public statement for my Company and always refer any requests to the Communications department. If I make any comments at public, trade or cultural events or on the Internet, I make it clear that I am voicing solely my own personal opinion. I consult the Company’s social media guidelines for advice on proper conduct in social networks.

 

Example

 

You read a comment on the Internet from someone who is critical of production methods in Asia, but the points raised are entirely unfounded. Even if you would like to correct the misrepresentation straightaway, contact the relevant department first, because this department is in a position to respond appropriately and comprehensively to such criticism.

Our responsibility in the workplace

 

It is in the fundamental interests of Georgiou-Botaris Automobile Couture to protect the health and safety of every employee.

 

The principle of protection and security also applies to employee and customer data as well as company-specific know-how and company assets. Georgiou-Botaris Automobile Couture's responsibility in the workplace specifically gives rise to the following principles:

Occupational safety and healthcare

 

Background

 

Georgiou-Botaris Automobile Couture is committed to its responsibility for the safety and health of its employees. We provide occupational safety and healthcare in line with the provisions of national regulations and with the occupational health and safety policy of the Company.

 

Corporate principle

 

We preserve and promote the health, performance and job satisfaction of our employees through continuous improvements in the working environment and a raft of preventive healthcare and health promotion measures.

 

My contribution

 

I comply with the occupational health and safety rules. I never put the health and safety of my colleagues or business partners at risk. I take all appropriate and statutory precautions to ensure that my workplace always enables safe working. I make an active contribution to maintaining and promoting my health by voluntarily participating in preventive healthcare and health promotion measures.

 

Example

 

You notice that a machine in your department has an electronic fault. Take the machine out of operation and make sure the “out of order” sign is clearly displayed. Ask the appropriate department to repair the machine because repairing electrical equipment yourself is not permitted and could be dangerous.

Data protection

 

Background

 

There are special statutory rules to protect privacy when dealing with personal data. As a general rule, collecting, storing, processing and other use of personal data require the consent of the person concerned, a contractual arrangement or on some other legal basis.

 

Corporate principle

 

We protect the personal data of employees, former employees, customers, suppliers and other affected parties. We collect, gather, process, use and store personal data strictly in accordance with legal provisions.

 

My contribution

 

I ensure that personal data is collected, stored, processed or used in any other way only with the consent of the person concerned, under a contractual arrangement or some other legal basis. All data processing components must be secured in such a manner that the confidentiality, integrity, availability, verifiability and reliability of such sensitive data is guaranteed, and that unauthorized internal or external access is prevented. When in doubt, I contact my superior or the appropriate Data Protection Office.

 

Example

 

You have organized a seminar for Georgiou-Botaris Automobile Couture with external participants and receive personal data from the participants for it. A colleague asks you to pass the addresses on. Do not pass this data on without consulting one of the contacts mentioned above. As a general rule, data may be used only for the purpose for which it was communicated.