Code of Ethics

The Code of Ethics governs all activities performed by Stratlane’s personnel, partners and subcontractors.

1. Purpose, scope and users

Scope of Applicability: The Stratlane Code of Ethics is binding for all Stratlane employees worldwide.
All Stratlane employees shall receive the Stratlane Code of Ethics as an electronic copy (via e-mail as a PDF file) or as a printed version in a language that they are familiar with. In addition to this, the Stratlane Code of Ethics is always available on the Stratlane Website for ease of reference.
All Stratlane executives shall ensure strict observance of the Stratlane Code of Ethics among their members of staff and aim to be role models for their employees. No employee should suffer any disadvantage as a result of complying with the Stratlane Code of Ethics.

2. Reference documents

  • ISO/IEC 17021
  • ISO/IEC 17021-1:2015

3. Our Compliance Principles

Our 10 Compliance Principles are:

  • We operate lawfully
  • We avoid conflicts of interest
  • We do not tolerate corruption
  • We play fair
  • We handle information carefully
  • We follow export control and customs laws
  • We observe occupational health and safety standards
  • We manage assets carefully
  • We do not support money laundering
  • We do not tolerate discrimination

3.1. We operate lawfully

All applicable legislation must be observed in all business decisions and operations both at home and abroad. Sustainable business for everyone’s benefit can only be achieved with fair competition and strict conformity with the law. Corruption, cartels, embezzlement and fraud distort competition and increase costs, which may cause significant fines, reputation damage and, ultimately, could also endanger the employment at Stratlane. In view of this, we refuse to conduct unfair and/or dishonest business practices and carry out our business in a manner that is free of bribery and corruption. It should be noted that breaches of the law will not be tolerated and may result in disciplinary action.

3.2. We avoid conflicts of interest

Independence, integrity and transparency of our services are the foundation of our customers’ trust in us. However, a conflict of interest can severely damage that trust. A conflict of interest can arise when the private interests of a Stratlane employee could or do conflict with the interests of Stratlane. For instance, if a Stratlane employee has a shareholding in a supplier, customer or competitor of Stratlane, or an employment of any kind with a third party this may lead to a conflict of interest.

3.3. We do not tolerate corruption

Corruption distorts competition with the business world and causes damage to both individuals and society. Corruption can also result in actions being made under criminal and civil law for Stratlane employees as well as for Stratlane. This could include anything from a prison sentence to fines. Corruption is strictly prohibited in all countries in which Stratlane operates, and any violations of such are therefore not in the beneficial interest of the company. This applies to all employees, regardless of their nationality.

3.4. We play fair

Fair and free competition between companies is the guarantor for freedom of business behavior and effective consumer protection. Fair and free competition is protected by antitrust laws, which forbid cartels and abuse by market-dominating companies. Mergers of companies are also subject to merger controls under certain conditions.

3.5. We handle information carefully

The exchange of information and the use of our know-how are part of our daily commercial activity. It is important to handle information correctly and transparently in order to protect it, our company and our customers. Records and financial integrity Internal and external transparency, as well as correct and truthful reporting, is the standard of our entrepreneurial action and behavior.

3.6. We follow export control and customs laws

We follow the export control and customs regulations in all countries in which we do business
As a worldwide operating enterprise, Stratlane is subject to various national and international foreign trade regulations. These treaties and laws regulate the import, export and/or transfer (which can also take place electronically) of goods, technologies, services, capital and currency over particular international borders right up to the complete banning of trade with particular countries (embargo). Any trading restrictions and bans can arise from the character or purpose of use of the goods or services, the country of origin or country of use, or the business partner. The export of goods with both civilian and military uses (so-called dual use goods) also requires approval. Export controls cover exchanges between Stratlane subsidiaries too.

3.7. We observe occupational health and safety standards

The protection of our employees is of primary importance for Stratlane, since our employees are essential for us as a provider of technical services.

3.8. We manage assets carefully

Tangible and intangible assets of Stratlane (e.g. cash, machinery, know-how, patents and trademarks) constitute Stratlane’s business assets, which may only be used for business purposes. The same applies for the property of Stratlane business partners, with whom Stratlane employees come into contact in the course of their work.

3.9. We do not support money laundering

Money laundering occurs when illegally acquired financial means (from criminal activities like organized crime, bribery, corruption or terrorism) are smuggled into the legal, financial and economic circulation in order to disguise their real origin or the identity of the owner.

Stratlane only maintains business relationships with respectable business partners, whose business activities comply with all applicable laws and whose funds derive from lawful activities. For this purpose, we at Stratlane observe money laundering regulations at home and abroad, and keep our distance from businesses that are used for money laundering.

3.10. We do not tolerate discrimination

Stratlane is a worldwide operating company that is active in various countries, all with different cultures. At Stratlane, our attitude is that people of different ethnic origin, religion, world view, race, age, disability, gender or sexual identity are invaluable for our success. No employee or business partner may be directly or indirectly discriminated against, sexually harassed or personally disparaged on the basis of any of these attributes, and will be protected by applicable equality legislation.

4. Compliance Reports

4.1. Who can report a compliance violation?

Stratlane employees, external service providers, business partners or other third parties can report situations that indicate a breach of the Stratlane Code of Ethics.

4.2. How can compliance violations be reported?

Reports can take the form of a letter, an e-mail or a telephone call to a Stratlane Compliance Officer or Ethics Point.

4.3. May reports also be anonymous?

Stratlane explicitly permits anonymous reports in order to ensure a credible, effective and transparent compliance program. This also includes whistleblowers who fear that disadvantages or reprisal may be a result of reporting a compliance violation. Anonymous reports should contain as much detailed data and facts about the compliance violation as possible, so that the indications can be investigated to the required extent in the course of an internal investigation.

4.5. What happens after the report?

After a report is received, this will first be checked for coherence and plausibility. Should the two points be fulfilled, an internal investigation will then be set in motion. The Compliance Officer is responsible for ensuring that the events reported are investigated properly and conclusions reached. If required, the authorities will also be involved. To the extent that it is compatible with the required protection of confidential data, you, as the whistleblower, will be informed about the outcome of the procedure when the investigation is completed.

4.6. Implementation and Questions

The Compliance Officer is responsible for implementing the Stratlane Code of Ethics. They will be supported in this regard by the management of the respective Stratlane subsidiaries. The Stratlane Code of Ethics describes merely the principles of lawful and honest behavior at Stratlane. For that reason, it cannot answer all difficulties you may come across in your daily work. If, in a particular case, you are uncertain how to apply or to interpret the Stratlane Compliance Principles, or have other questions, please consult a Compliance Officer. The worldwide implementation of the Stratlane Code of Ethics is regularly checked by our internal auditors. In addition, all senior managers are required to provide an annual compliance declaration, which is included in their personnel records.

4.7. Who to Contact

You can also contact us at: [email protected]

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