Code of Conduct
As Gerresheimer, we are committed to integrity and act responsibly, prudently, and in a value-based manner. With our Code of Conduct, we create an ethical code of conduct derived from our corporate values, TRIBE.
We respect human rights, assume social responsibility and stand for ethical business practices.
The Code of Conduct provides guidance for actions and decisions in our daily work. It applies to our corporate bodies, managers, and employees worldwide.
Compliance Management System (CMS)
A Compliance Management System (CMS) was introduced in our Group back in 2009, which has since been continuously developed and adapted to current requirements and changes in the law.
Our CMS focuses on the following areas:
Avoiding antitrust and competition law risks
Combating corruption and money laundering
Compliance with data protection laws and guidelines
Export Control
Insider law
Key elements of the CMS include our compliance program, classroom training, web-based e-learning programs, and a whistleblower system that allows for anonymous reporting upon request.
Corporate Social Responsibility
Collaborations and partnerships play an important role for us in underscoring our commitment to being part of relevant, forward-looking discussions and advancing integrity and sustainability issues in a recognized and collaborative framework.
OECD Galvanizing the Private Sector (GPS)
Gerresheimer has joined in 2024 the Galvanizing the Private Sector (GPS) initiative, and appointed its Head of Compliance as Gerresheimer's representative on the GPS Anti-Corruption Leaders Hub.
GPS is a public-private cooperation initiative to mobilise the private sector in the fight against corruption. It is driven by the OECD in partnership with the U.S. Department of State.
Businesses are well-placed to inform policy priorities and to develop novel solutions to corruption and integrity challenges. Engagement between the private and public sectors, however, tends to be limited to ad-hoc interactions, often in a sensitive enforcement context. GPS seeks to unlock the creativity and potential of the private sector by providing a collaborative forum for sustained dialogue and innovation on anti-corruption and integrity between business and governments.
Gerresheimer has been an active corporate member of DICO – German Institute for Compliance e.V. since 2024. Since its founding in 2012, DICO, with its more than 1,000 members, mainly companies, has pursued the goal of setting and further developing standards for compliance practice.
Compliance Organization
Compliance is managed by the Group Legal & Compliance department based at the headquarters in Düsseldorf. In order to meet the requirements of legislation and market requirements, the position of Head of Compliance was created and staffed in 2022. Each company in our Group has appointed a person who is responsible for compliance in that company. There is also a Compliance Officer at locations with their own legal department. The Head of Compliance regularly reports to the Audit Committee of our Supervisory Board on the current status of compliance. The Head of Compliance also works closely with the Internal Audit department, which also regularly audits individual components of the CMS.
Gerresheimer Compliance Program
Our CMS is intended to support our employees in applying laws and company guidelines correctly and thus protect them from violations. All guidelines, documents, templates, etc. are therefore easily accessible to all employees on the intranet site. The available guidelines include Compliance Organization, Internal Investigations & Whistleblower Protection, Conduct during Searches, Antitrust Law, Capital Market Law, etc. Most of the guidelines are available in 10 languages to provide employees worldwide with easy access to the information.
Employee training
In accordance with our Compliance Organization Policy, we conduct training courses both in person and online as e-learning. In the classroom training sessions, employees are given an overview of our CMS and are provided with information on where to find further material.
The e-learning modules cover the topics of compliance in general, data protection, protection against corruption, fraud prevention, fair competition and responsibility in exports. All modules are available in 10 languages.
Receipt of information and whistleblower protection
Another important component of the CMS is our procedure for receiving and processing reports and protecting whistleblowers.
We have set out the details of the options for submitting information to us (reporting channels), how we process such information and how we protect whistleblowers in Rules of Procedure. These can be downloaded in numerous languages.
Our procedures for receiving reports include the electronic whistleblower system. It enables a direct dialog with the Head of Compliance via the Internet worldwide and around the clock. The whistleblowers decide for themselves whether they wish to remain anonymous. To make access as easy as possible, the whistleblower system can be used in all languages relevant to the
Export control
We use a license from a specialist service provider to ensure that we are always up to date with regard to possible sanctions. In this way, the relevant databases of our ERP system are continuously checked with regard to current direct sanction measures of the EU, the USA and various international sanction regimes. This system is used worldwide within our Group.
