Dear Ladies and Gentlemen,
Dear employees,
Culture is the foundation of the KLS Martin Group, because our values of co-creation, respect and appreciation, personal proximity, reliability, and variety shape our actions. At any time.
We see it as our mission to develop surgical solutions which inspire users and pay dividends. We provide surgeons with solutions which make the difference. This is owed to the dedication, precision and care which we invest in their development, manufacture and sales which become evident every time they are used. This confers on them a value which is higher than the price they cost. Be it that they offer a unique advantage. Be it that they render their users prolonged outstanding service due to their exceptional high quality, reliability, and availability.
This Code of Conduct provides a guide for our daily actions, helping us to fulfill our mission and ensure the success of the KLS Martin Group today and in the future.
I am counting on your contributions to the observance of our Code of Conduct and thank you for your support.
Sincerely,
Christian Leibinger
President
KLS Martin Group
effective as of January 1st, 2024
The present Code of Conduct is observed by all of us, i.e. the employees (including trainees, interns and working students), executives (including divisional, departmental and group managers) as well as the managing directors and shareholders of all companies, subsidiaries and representative offices of the KLS Martin Group, within the scope of our activities worldwide.
a. We comply with the relevant laws and regulations of the countries in which we operate. Furthermore, we observe all internal company regulations, such as work instructions, company agreements and guidelines.
b. As a company, we support the ten principles of the United Nations Global Compact. These include in particular the observance of human, labor and environmental rights and the prevention of all forms of corruption.
c. All managing directors ensure that legal and internal requirements are known and complied with in their areas of responsibility.
a. If we identify possible violations of legal regulations, internal guidelines or this Code of Conduct, we are encouraged to report them in order to remedy irregularities. For this purpose, we can inform our supervisor or use the KLS Martin whistleblower system, which can be accessed via the KLS Martin website https://klsmartin.integrityline.app
The KLS Martin whistleblower system can also be used by business partners and other whistleblowers.
b. Any information will be treated confidentially upon request.
a. When developing, manufacturing and marketing our products, we observe the applicable regulatory regulations and requirements for the marketing, provision and commissioning of medical devices.
b. To secure our long-term goals as well as quality and cost-effective manufacturing of our products, we use a Group-wide quality management system that describes the networking of processes in a transparent and systematic manner.
a. We comply with the laws and regulations of antitrust and competition law.
b. We do not enter into any formal or informal agreements with competitors to agree prices or unlawfully divide markets by industry, product, territory or customer.
c. We do not exchange information with competitors about distribution channels, conditions, prices, costs, offers, margins, individual customers or other matters relevant to competition.
d. We neither agree resale prices directly or indirectly with our customers, suppliers and other business partners (e.g. distributors) and also do not demand such. We do not participate in boycotts of customers or suppliers.
e. We will in no way unfairly give preference to or discriminate against our competing customers. In the case of tenders, we comply with the relevant regulations and, in particular, do not enter into any illegal agreements with competitors aimed at inducing a customer to accept a particular offer.
f. In our dealings with suppliers or other business partners in projects, we act in a cooperative and appropriate manner. The selection of a supplier or other business partner shall be based exclusively on our financial interests.
a. We comply with anti-corruption and anti-bribery laws and regulations. This applies in particular to the cooperation with business partners from the health care sector (e.g. medical institutions, physicians, nursing staff).
b. We neither offer nor promise unlawful advantages to our customers, suppliers, competitors or other business partners (e.g. authorities, development partners or specialist dealers) or their employees.
c. We refuse to accept unlawful benefits from customers, suppliers, competitors or other business partners as well as their employees or to have them promise us such benefits.
d. We refrain from granting or accepting gifts and invitations that go beyond socially acceptable levels.
e. We observe the internal guidelines and processes for the prevention of corruption of the respective companies in the KLS Martin Group.
a. We comply with the laws and regulations relating to proper accounting, financial reporting and the prevention of money laundering and terrorist financing.
b. We conduct business transactions (e.g. preparation of quotations, order confirmations, bookings, invoices, credit and debit notes) professionally.
c. We are committed to helping identify and prevent money laundering activities (e.g. by reporting suspicious transactions). If we must assume that payments are related to terrorist financing, we do not accept or make such payments.
a. We comply with the laws and regulations on foreign trade and customs law.
b. We comply with supply restrictions to certain countries or persons resulting from national law or UN embargo resolutions. We do not engage intermediaries to circumvent any restrictions.
c. We comply with the applicable customs regulations when importing and exporting our products.
d. If in doubt, we contact the logistics experts of the respective KLS Martin Group company and, if legally required, apply for an export permit from the relevant authorities.
a. We comply with the laws and regulations on data and information protection.
b. We respect the right to protect the personal information of employees, customers, suppliers and other business partners.
c. To prevent the loss, theft or damage to operational resources, we treat the tangible and intangible assets of our companies, including any intellectual property rights and confidential information, with due care.
d. We observe the internal guidelines for the IT safety guidelines of the respective companies in the KLS Martin Group.
a. We speak of conflicts of interest in all cases where personal interests or those of family members, relatives or friends come into potential conflict with a KLS Martin Group company. Examples of conflicts of interest include:
b. We contact our supervisor or the KLS Martin Group’s internal reporting body located in the department Legal & Compliance (compliance@klsmartin.com) if we identify potential conflicts of interest.
a. We ensure that at least two employees are involved in business processes. A second employee always checks the results of processes.
b. We observe the internal signature guidelines for the respective companies in the KLS Martin Group.
a. We comply with the laws and regulations of labor, human rights and environmental law.
b. Securing existing and creating new jobs is an important contribution to fulfilling our societal and social responsibility.
c. We reject child and forced labor.
d. We support the protection of our environment and comply with the relevant laws and regulations and go beyond these where this is economically justifiable.
a. We comply with the laws and regulations to protect occupational safety, health and equal opportunities.
b. We have implemented strict principles and processes in the areas of "Health and Safety" in the respective companies of the KLS Martin Group. This includes the instruction of all persons in these areas. Everyone is encouraged to work safely and protect themselves.
c. Employees from different nations work together in the respective companies of the KLS Martin Group. We respect them all, regardless of gender, religion or belief, culture or nationality, sexual identity, age or any physical or mental impairment. Nobody in our company is allowed to discriminate against employees. This applies in particular to the recruitment, remuneration, promotion, further training, retirement or dismissal of employees.
d. We want all KLS Martin Group employees to feel at home in their respective companies. We do not tolerate harassment of any kind or offensive conduct towards employees in personal conversations, on the telephone or in written contact with each other.
If possible violations of legal regulations, internal regulations or the KLS Martin Code of Conduct are identified, our employees, business partners and third parties can report these via our digital KLS Martin whistleblower system.
The KLS Martin whistleblower system can also be used to submit complaints about human rights and environmental risks as well as violations of human rights or environmental obligations caused by the business activities of a KLS Martin company or a direct supplier.
The KLS Martin whistleblower system is available at the following link: