The principles of governance at H-TEC SYSTEMS

The principles of governance at H-TEC SYSTEMS

As a company H-TEC SYSTEMS has a corporate responsibility to its customers, employees, investors, and the public. This corporate responsibility includes complying with laws everywhere and always, respecting ethical values and acting sustainably. Integrity and compliance are a fundamental part of the H-TEC SYSTEMS strategy and are practiced at all levels of the company and by all employees — the management, executives and all other employees.

As a subsidiary of MAN Energy Solutions, H-TEC SYSTEMS is integrated into the Integrity & Compliance Management System of MAN Energy Solutions. The compliance organization of MAN Energy Solutions supports H-TEC SYSTEMS in the execution of its integrity and compliance tasks and provides advice. The Integrity and Compliance Program focuses on integrity as well as white collar crime, especially anticorruption and the prevention of money laundering and antitrust law. The group-wide Integrity and Compliance Program is designed to

  • prevent compliance violations (prevention),
  • detect as early as possible compliance violations that may arise despite preventative measures (detection),
  • and respond quickly and efficiently to any compliance violations (response).
PREVENTION

PREVENTION

The aim of the Compliance Organization of MAN Energy Solutions is to further establish and promote awareness and understanding of responsible and honest conduct among all H-TEC SYSTEMS employees, suppliers and business partners. In order to prevent compliance violations, the Compliance Organization of MAN Energy Solutions has taken and implemented various measures in cooperation with MAN Energy Solutions:
 
Code of Conduct
The H-TEC SYSTEMS Code of Conduct applies to all H-TEC SYSTEMS employees — the management, executives and all other employees. The Code of Conduct is at the heart of H-TEC SYSTEMS’ corporate culture and sets forth specific and binding guidelines for situations in which managers and employees should pay particular attention to acting responsibly. The Code of Conduct uses examples to describe how conflict situations can be addressed in everyday business.
 
Code of Conduct for Suppliers and Business Partners
H-TEC SYSTEMS expects its suppliers and business partners and their employees to respect laws and behave responsibly and with integrity, everywhere and always. That is why H-TEC SYSTEMS has a Code of Conduct for Suppliers and Business Partners, which communicates the ethical standards that H-TEC SYSTEMS requires suppliers and business partners to uphold.
 
Communication
The Compliance Organization of MAN Energy Solutions continuously communicates across all levels of the organization. Integrity and compliance topics are regularly featured in H-TEC SYSTEMS’ company media, such as the Intranet. In addition, the Compliance Organization of MAN Energy Solutions informs and advises managers and other employees through trainings, the helpdesk service, and at internal conferences and meetings.
 
Compliance policies
H-TEC SYSTEMS has compliance policies, which establish requirements related to anticorruption, antitrust law, the prevention of money laundering and terrorism financing, and Business Partner Integrity. These policies contain binding rules for all employees throughout the Group.
 
Training program
H-TEC SYSTEMS has a robust Integrity and Compliance training program which covers all operations and employees worldwide. Key content includes information about the Code of Conduct and the Compliance Organization of MAN Energy Solutions. 
 
Exchange of experiences with experts
The Compliance Officers participate in regular exchanges on integrity and compliance topics with experts from industry and academia. Through memberships of the parent company ,MAN Energy Solutions, in external compliance-related initiatives, H-TEC SYSTEMS supports and encourages Integrity & Compliance initiatives individually and in partnership with other companies.
 
Helpdesk
H-TEC SYSTEMS offers a Compliance Helpdesk service to all employees, which they can use to address their integrity and compliance related questions directly to Compliance Officers via phone or e-mail. The queries made to the Compliance Helpdesk provide the Compliance Organization of MAN Energy Solutions with an overview of the most common questions that arise in the business. The knowledge gained from these questions is used to identify new risks and trends and to identify preventative compliance measures.
 
Monitoring
To ensure the sustainability of the Integrity and Compliance Program, the Compliance Organization of MAN Energy Solutions continuously reviews the Program’s effectiveness and efficiency, by tracking the implementation of measures and projects. 
 
Tone from the Top
The Executive Board of the H-TEC SYSTEMS is aware of its responsibility for integrity and compliance and is committed to fulfilling this responsibility. MAN Energy Solutions’ management and executives consider integrity and compliance to be an integral part of the corporate strategy.

DETECTION

DETECTION

The occurrence of legal violations within H-TEC SYSTEMS can lead to considerable risks for the H-TEC SYSTEMS GmbH and the affected employees. Integrity and compliance with the law therefore have the highest priority within the H-TEC SYSTEMS GmbH. In order to guarantee these values, H-TEC SYSTEMS has created clear and transparent processes that ensure that violations of the law are identified, clarified and immediately remedied internally.
 
Compliance risk analysis
The Compliance Organization of MAN Energy Solutions carries out periodic group-wide compliance risk analysis. The risk analysis takes into account information such as the number and size of individual Group companies, the business model, the customer and sales structure, country risk, and the structure of competition in the local market. In addition, the implementation of compliance measures and controls in the reviewed companies are audited internally.
 
Mergers and acquisitions (M&A)
To identify, prevent, and mitigate compliance risks during acquisition and divestment transactions, the Compliance Organization of MAN Energy Solutions is engaged in H-TEC SYSTEMS’ M&A projects. The Compliance Organization of MAN Energy Solutions undertakes compliance due diligence assessments on concerned entities, which are intended to detect any compliance risks that may arise.
 
Whistleblower system
H-TEC SYSTEMS offers a secure whistleblower system for providing information on potential compliance violations, which is accessible to all, employees, customers, suppliers and other business partners. This allows anonymous, safe, and confidential sharing of such information at any time and from anywhere in the world. Tip-offs are forwarded to an independent unit for investigation. All whistleblowers who acted in good faith are protected against discrimination and retaliation. You can find more information about the whistleblowing system here: www.volkswagenag.com/hint

RESPONSE AND RESOLUTE ACCOUNTABILITY

RESPONSE AND RESOLUTE ACCOUNTABILITY

H-TEC SYSTEMS has zero tolerance for compliance breaches. The right response to compliance violations and misconduct is essential for minimizing the negative impact of any breach, by holding those responsible accountable, and ensuring that our commitment to doing business with integrity remains firm.
 
Investigations by authorities
H-TEC SYSTEMS is also committed to cooperating closely with the responsible authorities. H-TEC SYSTEMS has a guideline for employees which emphasizes the importance of openness, transparency, and cooperation with authorities.
 
Continuous improvement of the Integrity and Compliance Program
The Compliance Organization of MAN Energy Solutions continuously develops and improves the Integrity and Compliance Program.

Downloads

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H-TEC SYSTEMS Code of Conduct

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Code of Conduct for Suppliers and Business Partners

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Integrity and Compliance brochure

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H-TEC SYSTEMS Quality Policy for external Suppliers

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Our Whistleblower System

Complying with statutory regulations and internal rules, and the principles laid down in our Code of Conduct and the Code of Conduct for Business Partners, has top priority at H-TEC SYSTEMS. The success of our company is based on Integrity and Compliance. To meet this standard, it is important to learn about potential employee or supplier misconduct and to put a stop to it. Therefore, we entrusted the Central Investigation Office of Volkswagen AG to operate an independent, impartial and confidential Whistleblower System on our behalf. 

A key pillar of our Whistleblower System is the principle of procedural fairness. It also guarantees the greatest possible protection for whistleblowers, persons implicated and employees contributing to the investigation of reported misconduct. This also includes offering opportunities for anonymous reporting and communication. We assure not to perform any steps in order to identify anonymous whistleblowers, who do not misuse our Whistleblower System.

Retaliation of whistleblowers and all persons who contribute to investigations at H-TEC SYSTEMS will not be tolerated. Persons implicated are presumed innocent until the violation is proven. Investigations will be conducted with the utmost confidentiality. The information will be processed in a fair, fast and protected process.

How do we process your report?

The qualified and experienced colleagues at the Central Investigation Office of Volkswagen AG examine every report for potential misconduct by a Volkswagen Group employee thoroughly and follow it up systematically. First, you will get a confirmation of receipt. The Central Investigation Office then assesses your report. This includes gathering facts particularly from the whistleblower. Only if this initial evaluation shows grounds for suspicion of a violation an investigation by a dedicated Investigating Unit will be started. Afterwards, the results of the investigation will be assessed by the Central Investigation Office and appropriate measures will be recommended. Information about the status (processing time varies depending on the subject of the procedure) and the outcome of the procedure will be given to you without undue delay.

Potential violations of the Code of Conduct for Business Partners by suppliers, including serious risks and violations of human rights and environment by direct and indirect suppliers, can also be reported to the Central Investigation Office -  as well as reports requiring otherwise immediate action. The Central Investigation Office will inform the responsible departments, who will process the issue accordingly. This particularly includes taking the necessary measures to minimize or end violations and/or risks.

Find more information on the procedural principles of the Volkswagen Group Complaints Procedure here

Making a report to our Whistleblower System

The Whistleblower System offers various channels to report potential employee misconduct or violations of the Code of Conduct for business partners in our supply chain that allow a swift review and reaction by our company if necessary. However this does not affect the statutory right to contact designated authorities.

ONLINE REPORTING CHANNEL

ONLINE REPORTING CHANNEL

You have the option of using a web-based communication platform bkms-system.com to contact the Central Investigation Office in many languages. This system is confidential and technically secured.

Even if your preferred language is not offered in the reporting channel, you can use any language to submit your report. You can also contact the Central Investigation Office in any language via e-mail or mail.

24/7 Hotline

24/7 Hotline

You can make a report at 365 days, 24 hours, using the international toll-free number: +800 444 46300

If your local telephone provider does not support the toll-free service, you can call the following chargeable number: +49 5361 946300

OMBUDSPERSONS

OMBUDSPERSONS

Volkswagen AG has appointed external lawyers to act as Ombudspersons. They advise on the Whistleblower System or ensure that reports from whistleblowers are forwarded anonymously to the Central Investigation Office if desired.

If you want to get in contact with the Ombudsperson you can find their contact details here:
www.ombudsmen-of-volkswagen.com

E-Mail

E-Mail

You can get in contact with the Central Investigation Office of Volkswagen AG via e-mail: io(at)volkswagen.de

POSTAL ADRESS/IN PERSON

POSTAL ADRESS/IN PERSON

Postal address:
Central Investigation Office
Box 1717
38436 Wolfsburg (downtown)
Germany

Please make an appointment in advance by writing an e-mail to: io(at)volkswagen.de

Questions or suggestions for improvement concerning the Whistleblower System can also be addressed to the Central Investigation Office. If you have been interviewed in terms of an investigation, you have the possibility to give feedback to the Ombudsperson as independent body. Furthermore, our responsible Compliance Officer can also be addressed in all matters of the Whistleblower System via compliance(at)man-es.com

External Reporting Channel of Germany

The German government has defined a designated authority, that also accepts reports on misconduct as external reporting channel. The external reporting channel is the Federal Office of Justice (Bundesamt für Justiz) (BfJ - Hinweisgeberstelle (bundesjustizamt.de)).

Do you have further questions about the H-TEC SYSTEMS Integrity and Compliance Program or our Whistleblower System?


compliance(at)man-es.com

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