Compliance Directive

Basic conduct requirements

All employees are obliged:

  • to comply with all laws, rules, company instructions and directives having a bearing on their own sphere of responsibility,
  • to conduct themselves in a fair, respectful and trustworthy way in all activities and business relations,
  • to honour and nurture the good name of the FSB Group,
  • to avoid conflicts of interest between business and private matters,
  • to refrain from gaining wrongful advantage for either themselves or others,
  • to observe the provisions governing industrial safety, environmental protection and data privacy,
  • to report compliance infringements to the applicable entity (the Executive) without delay.

All higher-grade staff are additionally obliged:

  • to judge employees solely on the basis of their work performance,
  • to ensure this Directive is conformed to in their sphere of responsibility.


Discrimination on grounds of race, ethnic origin, gender, religion, ideological persuasion, disability, age or sexual identity is strictly forbidden. This applies in particular with regard to dealings with colleagues, employees and business partners as well as to the appointment, promotion or dismissal of staff.

Intellectual property

The FSB Group respects the intellectual property of third parties, i.e. including trademark rights, registered designs, patents and proprietary rights.

Policy on bribery and corruption

It is strictly forbidden:

  • to offer, promise or afford holders of office either at home or abroad undue personal advantage for the exercising or non-exercising of an official duty,
  • to offer, promise or afford employees or representatives of companies either at home or abroad unlawful personal advantage,
  • to arrange for acts of bribery to be perpetrated with the aid of other persons such as relatives, friends, agents, consultants, planners or intermediaries,
  • to support wrongful actions performed by others.

Avoiding conflicts of interest

All employees are required to keep their private interests and those of the FSB Group strictly separate. The very semblance of a conflict of interests is to be avoided. They are, in particular, to refrain from:

  • awarding contracts to persons close to them such as spouses, common-law partners, relations, friends or private business partners,
  • awarding contracts to companies in which persons close to them hold key posts,
  • awarding contracts to companies in which persons close to them hold stakes of 5 % or more,
  • carrying out sideline activities for rival companies,
  • carrying out sideline activities for business partners.

Exceptions must be endorsed in writing by the Managing Director responsible.

  • Employees wishing to take out a direct or indirect stake of 5 % or more in a rival company, or who have already done so, are required to report this to the Executive. It will then be checked whether there is any conflict of interests.

Combating money laundering

The FSB Group works solely with serious business partners operating within the framework of statutory regulations and making no use of illegal financial resources.

All employees are required to comply with money laundering legislation and to submit written reports of suspected instances of money having been laundered without delay both to their respective Accounts Department manager and to the Executive.

Work with customers and suppliers

FSB expects employees, customers and suppliers alike:

  • to comply with all laws in force,
  • to resist corruption,
  • to observe human rights,
  • to comply with the laws on child labour,
  • to observe the legislation governing international commerce,
  • to comply in particular with bans on exports and imports as well as with embargo regulations,
  • to protect the health and safety of all employees,
  • to comply with the relevant domestic laws and international standards on industrial safety, environmental protection and data privacy,
  • to ensure that these points are also implemented and observed within their own delivery chains.

Invitations, gifts and other personal benefits

Employees may not generally demand, expect to receive, or accept personal benefits either for themselves or for persons close to them. They may only accept personal benefits (e.g. gifts or invitations to restaurants or sporting events) where there is no impression of their being expected to do anything in return.

The personal benefit must lie within the bounds of standard business practice and may not be in contravention of any law.

Gifts to a total value of €35 per person and year may be presented to business partners and can be claimed as operating expenditure in Germany (Section 4 (5) Income Tax Act EStG). It is additionally permissible to dispense trivial benefits (calendars, ballpoint pens, pendants etc.) of less than €10 per item, based on the cost of either procurement or manufacture.

Industrial safety, environmental protection and data privacy

Personal data may only be collected, used and stored in conformity with the applicable data protection laws. Company and transaction-related data are to be treated confidentially and may only be used in the context of a given remit.

Conduct towards rivals

  • Competition and antitrust laws are to be adhered to.
  • No deals on prices, quantities and terms are to be struck with rivals.
  • No deals on dividing up the market are to be struck with rivals.
  • Contacts with rivals are generally to be confined to the absolute minimum necessary.