Accurision GmbH
Code of Business Conduct

Principles of lawful conduct


Accurision GmbH develops robust, high-precision satellite-based positioning systems.

Our basic principles include innovation and quality as well as the principle of legality which obliges us to respect the laws of the countries in which we operate.

We are convinced that reliability, trustworthiness, integrity and particularly legality are key elements of commercial success.

We expect all of our staff members to follow the principle of strict compliance with all legal requirements. No infringement of any applicable law will be tolerated in our company, and no exception shall apply to this rule.

In order to emphasize the great importance of this principle, we have concisely framed our view on legal requirements and ethical principles in the “Code of Business Conduct” (COBC).

The COBC represents a binding scope of action for all our staff members and outlines the basic standards. These applicable standards are complemented by binding company policies and instructions.

This shall not justify any third-party rights.

Gunnar Fleisch
Managing Director
Accurision GmbH

§ 1 Principles

Lawful conduct

We support the principle of strict legality for all acts, measures, contracts and other operations in our company; this also refers to settlement of owed taxes, obtaining the necessary official approvals, the respect of trade, financial and payment restrictions as well as close attention to third-party rights.

This principle is not only based on the consideration that violations might give rise to serious business disadvantages through criminal prosecution, fines or claims for damages; we support the principle for exclusive lawful conduct irrespective of whether or not our company derives a benefit therefrom.

It is strictly prohibited to cause third-parties to commit unlawful acts or to participate deliberately in such acts.

Responsibility for the reputation of the company

In the exercise of their duties, all staff members must have in mind the reputation of the company.

Conduct towards staff members and fair working conditions

We support a climate of openness and mutual respect and thus create an atmosphere that will enhance initiative and commitment, satisfaction and pleasure at work. Together with our staff members, we will agree on goals, define clear tasks and create spheres of responsibility providing for free space. We are aware of our social responsibility and work and decide in conformity with the principles of human fairness.

We will not tolerate any mobbing activities, discrimination and will not allow harassment of our employees. All staff members are working in our company on their own free will and irrespective of their gender, their origin, their religion or their cultural background.

We adhere to the working hours and wages prescribed by law, especially to the provisions of applicable collective agreements and guarantee the compliance with all regulations concerning health and safety at the workplace.

We also expect our suppliers and business partners to offer their staff members fair working conditions and fair pay.

We are committed to the prohibition of any form of forced labour. This means all types of work or services which a person might be forced to perform under the threat of punishment or which persons do not perform on their free will.

We presuppose that our suppliers and business partners also will not allow any form of forced labour in their companies.

We are committed to the prohibition of any form of child labour. When employing minors, we will conform to the minimum age for admission to employment according to national regulations.

We presuppose that our suppliers and business partners also will not tolerate any form of child labour in their companies. We expect our suppliers and business partners to not have children execute any hazardous works and to not impede the education of children through their employment.

Avoidance of conflicts of interest

We expect our staff members to act in our company’s best interest. If potential or actual conflicts of interest occur, for instance if personal interests as well as family or other ties preclude the interests of the company, the management must be informed in order to arrange for appropriate measures that will permit to settle or prevent a conflict of interest.

§ 2 Handling of information and protection of business secrets, intellectual property and other company assets


All and any records and reports must be correct and truthful. The principles of diligent accounting and reporting must be observed.


Operational and business secrets must be treated confidentially and must be protected.

Data privacy and information security

The protection of person related data, particularly those of staff members, customers and suppliers is of particular importance to us. We will only collect or process person related data if such a collection or processing is absolutely required for the fulfilment of the respective work task or required by law. Person related data may only be collected with the consent of the person involved or with a legal admissibility.

The security of all business data must be guaranteed in all business processes while incorporating all relevant legal requirements.

An appropriate standard in accordance with the state of the art must be observed for the technical prevention of unauthorized access.

Protection of company assets

Company assets must be protected through a diligent handling of company property, intellectual property and information. Loss or damage must be prevented. Equipment and information systems of the company are reserved for business-related purposes.

§ 3 Conduct towards business partners and third parties


We will deal in a competitive and fair manner with our business partners. We will define an unambiguous scope of performance with our business partners in order to prevent any misunderstandings and ambiguities. We will keep to commitments and agreements in order to be a trustworthy partner. We will negotiate on a price and performance orientated basis as well as on a competitive basis and basically, we are open to all new business partners.

We will deal with our business partners in a fair and partner-like manner and we will not act pretentiously or arrogantly.

Competition and anti-trust law

Each employee is obligated to comply with the rules of fair competition within the framework of the statutory provisions. Between competitors especially divisions of territories or customers, agreements or exchange of information regarding prices / price components, supply relationships and their terms and conditions as well as capacities or bidding approaches are inadmissible; the same shall apply to the exchange of information on market strategies and participation strategies. In general, not only written contracts, but also verbal agreements or tacit and conscious parallel behaviour are not allowed. Exchange of agreements and information on research and development projects shall only be admissible in very limited exceptional situations. The market position of the company shall in no case be unlawfully used to enforce for instance price discriminations, supply of not requested items or the refusal of a supply.

Supplier and customer relationships

We select our business partners exclusively on the basis of objective business-relevant criteria and we take care that our business partners comply with the same principles of conduct regarding business practices and ethics as we do.

Agreements with customers and suppliers must be complete and unambiguous and must be documented inclusive of all subsequent amendments and modifications. This shall also apply to regulations such as, for instance, the payment of premiums, advertising and sales promotion allowances.

The internal regulations regarding the application of dual control (dual-control principle) as well as the separation of executive and monitoring functions must be strictly observed by all staff members. Suppliers must be selected exclusively on a competitive basis after the comparison of prices, quality, performance and appropriateness of the offered products or services.

Corruption, gifts and other benefits

Agreements or side agreements relating to an accepting advantage or privilege of individuals in connection with the arrangement, awarding, supply, execution and payment of orders are inadmissible. Staff members who let themselves be influenced surreptitiously by customers or suppliers in a dishonest way or who try to influence customers or suppliers in a dishonest way, will – regardless of any criminal law repercussions -be disciplined and held accountable under employment law.

Attempts of suppliers or customers to influence staff members of our company in their decision in a dishonest way, must be notified to the management. On a case-by-case basis, reasonable reaction must be taken for instance through order blocks or contract termination.

Commissions and remunerations that are paid to official distributors, agents or consultants, must be in an appropriate and commensurate proportion with their activities. It is not admissible to agree on performances where it must be supposed that they are determined fully or partially by the payment of bribes. Agents or other intermediates mandated by our company to obtain orders or approvals, particularly official distributors, agents, customs agents and consultants must commit themselves explicitly in writing to abstain from bribery and do not accept any bribes.

Accepting or giving gifts or other grants (for instance participation in events without any direct business purpose) inclusive of invitations (by and to suppliers or customers) must be extremely restrictive. The financial framework for such acts must be determined in a way that the accepting by the recipient must not be concealed and he will not find himself in a binding dependence. In cases of doubt, the written consent of the management must be obtained.

§ 4 Conduct towards public officials and politically exposed persons/parties

In has to be taken into account that the law provides for less severe requirements regarding bribes to public officials. We will not grant any payments or non-cash benefits to public officials, politically exposed persons or political parties.

In general, we will refrain from granting any payments to officials or public officials with the aim to accelerate official procedures or decisions.

§ 5 Trade restrictions

Various national and international foreign exchange and foreign trade control laws restrict or forbid the importation and exportation of goods or services.

These restrictions do not only refer to the nature of the products but also to the country of origin or destination and in some cases to the person of the customer (embargo). Similar restrictions may also concern the exportation of technology or software. For some determined states there are country-specific embargos.

As soon as a state lays an embargo on another state, neither private persons nor companies of this state are allowed to export goods and services to the relevant state (and/or its citizens or inhabitants) not to import such goods and services from this state or to participate in any way whatsoever in such an exportation or importation.

Existing trade restrictions must be strictly observed by all staff members. Any required clarifications must duly be executed.

§ 6 Product quality and safety

Quality, innovation and performance are of highest priority to us.

Our aim is to meet the high requirements of the customers regarding quality and safety; we endeavour to implement thoroughly and sustainably all optimizations required to these purposes. If, despite all our efforts, shortcomings will occur, we will effect remediation in conformity with the legal requirements and contractual duties.

§ 7 Industrial safety, health protection, fire precautions and environmental protection

All staff members are obliged to avoid any hazards to people and environment, to reduce to a minimum all environmental impacts and to use natural resources sparingly. Processes, manufacturing sites and operating equipment must comply with the applicable legal and internal requirements regarding industrial safety as well as with the provisions on health protection, fire precautions and environmental protection.

§ 8 Information and training

Staff members will regularly be informed on current issues in connection with the present COBC. Specific trainings will be offered to staff members on certain topic areas (for instance: product liability, anti-trust law, labour law, environmental law) and on selected hazard areas (for instance distribution, acquisition).

§ 9 Communication of irregularities

Each employee is entitled – and within the framework of his work contract duty to prevent damages of his employer, the employee is even obligated – to communicate circumstances that might imply an infringement of the regulations contained in the present COBC as well as in otherwise applicable company guidelines and instructions; this may also be done anonymously. Such information will be verified and, where required, corrective measures will be taken.

It is guaranteed that staff members who will report actual or supposed infringements, will not face any disadvantages therefore.

§ 10 Monitoring and update

Each staff member is responsible for the respect of the regulations contained in the present COBC as well as of further in-house company regulations in his sphere of responsibility.

If the present COBC is updated, all staff members will immediately be informed.

November 2018