• CSR 3
  • CSR 3
  • CSR 4
  • CSR 1

Our Social Responsibility

Code of Conduct of Losberger

Our Code of Conduct constitutes the orientation framework for all people working at Losberger. This clear commitment to the observation of legislation and laws as part of our self-awareness is a characteristic feature of all the staff members of Losberger all over the world, surpassing the borders of countries and cultures. They all contribute not just to making Losberger successful commercially but also to making it a company that always operates in line with its social responsibility obligations. The combination of entrepreneurial activity and ethical principles is of fundamental importance and the key to lasting corporate success.



1. Observation of the law and internal guidelines

Losberger follows the principle of strict legality for all actions, measures, contracts and other procedures of Losberger. The same is also expected of the group’s business partners. The staff members of Losberger should be aware that any violations of the law will have legal consequences both for an individual staff member and also there might be consequences for the Losberger group as a whole. All staff members therefore should observe the corresponding valid legal provisions and internal guidelines. Punishable violations of the law should be avoided by all means. The observation of the valid legal regulation takes precedence over any differing instruction issued by a superior. In cases of doubt, a legal expert within the company should be consulted.

All staff members of Losberger should familiarize themselves with the laws, regulations, other legal provisions and guidelines that are relevant to their area of activity. The employer provides information to the staff members on the legal norms relevant to them by conducting regular training sessions or providing information bulletins.



2. Fair competition

Competition law has the objective of ensuring and upholding free and fair competition in the interests of all market participants.

Provisions and prohibitions of competition law particularly relate to the prohibition of arrangements between competitors on prices, territorial allocation, customer protection or production volumes as well as the prohibition of the misuse of market dominance.

Therefore it is strictly forbidden to make agreements or arrangements of any kind – be it in written or verbal form - with competitor companies and/or people associated with competitor companies who have and/or could have as their object or effect the prevention, restriction or distortion of the competition. “Competitor companies” are all companies with whom we compete in sales or purchasing both within the country and abroad.

The implementation or adherence to practices which may have been “tacitly” agreed and which have or which could have as their object the prevention, restriction or distortion of the competition in the sense described above is strictly forbidden.

The above-mentioned provision applies in particular (however not exclusively) to agreements and/or arrangements regarding


  • Delivery or offer prices as well as purchase prices
  • Delivery quantities or quotes as well as purchase quantities or quotes
  • Non-delivery or limited delivery to customers as well as paying no attention or limited attention to suppliers
  • Non-submission of offers and/or the submission of offers with agreed content
  • Abstaining from the attempt to poach the customers of our competitors or similar practices
  • Other agreed measures against other competitor companies

irrespective of whether such agreements or arrangements and/or differently agreed practices are of a general nature or are limited to specific individual cases (such as, for example, certain customers, certain areas, etc.).

Contracts or other agreements with competitor companies may only be concluded within the framework of the normal course of business (for example orders placed with competitor companies in the event of production bottlenecks). All other contact and/or agreements with competitor companies should be kept to an absolute minimum, i.e. only in cases where it is absolutely essential. These principles also apply to the participation and involvement in board meetings or similar meetings with the representatives of competitor companies.

Violations of competition law may be punished by the imposition of stiff fines that can jeopardize the continued existence of the company.



3. Prohibition of corruption and granting of an undue advantage

Corruption and the granting of an undue advantage – irrespective in what form – will not be tolerated in our company. In connection with our business activity we cannot ask for any personal advantages for ourselves or third parties and basically we cannot accept, offer or grant personal advantages, even if they are intended for third parties, if they give the impression that an (attempted) improper influence has been exercised. This applies particularly to the initiation, assignment or processing of an order, irrespective of whether the order was transacted with a private individual, a company or an authority. This also applies to countries where there may be local customs differing from this.

A “usual practice" or differing local customs are not an excuse or justification for oneself being corrupt or corrupting others. Statements to the effect that certain things “have always been done this way" or that “others do it this way too" are equally unacceptable. The goal should be to promote the company through quality and integrity even if in individual cases we lose out on orders and/or sales. The board of management accepts this approach because it is determined to prevent corruption and the granting of undue advantages and to tackle these problems with resolve. Violations of this will be severely punished. It is not permissible for the misconduct of an individual staff member to jeopardize the existence of the company. Corruption and the granting of undue advantages run contrary to the interests of our company.


When a staff member is confronted with an offer or request involving the above-mentioned practices, he/she should report it immediately to the relevant person in charge of compliance and agree how to proceed with him/her.

Internal guidelines on gifts apply in addition to this Code of Conduct with respect to offering and accepting of gifts and invitations. These guidelines stipulate in detail which gifts and invitations may be offered and accepted.



4. Safety and responsibility for the environment

The prevention and safe containment of dangers to people and nature is an important element in responsible behaviour. This applies to all areas in our company and in particular to production. When weighing up production costs and product safety, the decision taken should always be in favour of safety.


The observation of all safety precautions, irrespective of whether they have been stipulated by the law, issued by the competent authorities or are part of company guidelines is inalienable. Everyone is jointly responsible for safety in his/her working environment.

Environmentally-friendly behaviour for us is not just a corporate obligation but also an important prerequisite in order to be able to preserve natural resources and thereby our operating efficiency and competitiveness in the long term. Our approach to the environment is to minimise the use of resources and any negative impacts on our environment. Observation of the environment protection guidelines applicable in each case is considered to be a minimum standard.



5. Social responsibility

The observation of human rights and of fundamental social standards is an important principle for humans to co-exist together harmoniously. We follow this principle without limitation. Working conditions in all areas must be such that the observation of these rights and standards is constantly guaranteed.

In this respect the prohibition of child and forced labour as well as the granting of appropriate wages for working hours that comply with the respective legal regulations and industry standards are of paramount importance.



6. Prohibition of discrimination

All staff members have the right to be treated in a fair, polite and respectful manner by superiors and colleagues.

No one should be discriminated against, in the sense of being disadvantaged without factual reason, on the basis of race or ethnic origin, gender, religion or world view, disability, age or sexual orientation or on the basis of other personal characteristics.

We are all obliged to respect the personal dignity and sphere of other staff members. Harassment and any form of unwanted body contact are forbidden.

Should a staff member find himself/ herself in a situation where he/she is being discriminated against/harassed or if he/she becomes aware of such a situation, he/she can at any time turn to the relevant person in charge of compliance or to the works council.



7. Protection of company assets, intellectual property and commercial secrets

The assets of Losberger may only be used for business purposes. As a “trustee” each of us is obliged to protect them from loss, damage or theft. Even the office and work materials, samples of goods and products are company assets. If company assets inexceptional circumstances may be used privately such as, for example, company cars, telephone, etc. then this will be stipulated explicitly in internal guidelines.
Each of us is responsible and should undertake all necessary steps to also protect the intellectual property of Losberger such as, for example, patents, trademarks or know-how from the attacks of third parties or loss. Conversely, we must also respect the intellectual property of others.

Commercial secrets and other company-relevant information are confidential, must be treated with all due care and attention and protected from disclosure to unauthorised people. Staff members who have access to commercial secrets and confidential information must not pass this information to third parties or use for purposes other than those associated with work.


8. Avoidance of conflict of interests

Losberger considers it to be essential that staff members do not place themselves in situations where there could be a conflict of interests. Therefore any conflicts between their personal interests and the interests of Losberger should be avoided. Only factual criteria, such as, for example, quality, price, service and sustainability count within the framework of business relations with third parties. Even the mere semblance of conflicts of interest should be avoided.

Therefore everyone of us should report to his/her superior the intended acceptance of a mandate in a different company as well as the acceptance of secondary remunerative employment or the intention to take up an active entrepreneurial activity outside of the company. The same reporting duty to the superior and the requirement to obtain the consent of the board of management also apply to capital and profit sharing in non-listed companies that are the competitors of Losberger.

Staff members should bear the image of the company in mind when expressing their own personal opinions in public.

Conflicts of interests can also arise between the group companies of Losberger. If such conflicts of interest arise or if there is a threat of such conflicts of interest (e.g. during the conclusion or implementation of contracts with other group companies) a solution with the respective board of management should be sought.



9. Complete, truthful book-keeping according to the law

Conducting business transactions including the use of company assets or funds is only allowed when the corresponding procedures are properly recorded and accounted for.

All entries in books and documents belonging to Losberger should be truthful as well as complete and accurate. They should be recorded without any omissions and in accordance with the valid accounting guidelines.

Payment requests as well as payments must only be made and/or undertaken exclusively in the interests of the company and only for the purposes allowed by the law. They should correspond to the relevant payment documents.


10. Data protection

Losberger shall undertake to respect the private sphere and integrity of its staff members and business partners.

We adhere to strict standards with regard to the processing of the personal data of our staff members or business partners. All personal data that Losberger collects and stores is processed exclusively for the required purpose, in a traceable manner, carefully and in accordance with the respective applicable data protection laws.

Access to personal documents is restricted to Losberger staff members and people who have the requisite valid authorisation and a justified commercial interest in such an inspection. Confidential staff data should not be passed to anyone outside of the company without the corresponding authorisation or legal reason.


11. Economical use of the company’s resources

Economical use of the company’s resources should be regarded as a matter of course. With every use of physical or financial resources but also of HR resources, it should be checked whether this is being done in the interests of the company.


12. Ambassadors of the company

We all are perceived in our actions as the representatives of Losberger. Every single day we should remind ourselves of this. Behaviour which could damage the reputation of the company will not be tolerated. While we contribute through our work and our personal behaviour to the positive perception of Losberger, we are also supporting the commercial success of Losberger.




Bernd Christian
Director Human Resources & Chief Compliance Officer

E-Mail: B.Christian@Losberger.com


Code of Conduct of the Losberger GmbH 

138 KB