Code of Conduct
Fronius International GmbH Group Directives
Specified in Controlled Docment for this pdf: CS-000007_Code of conduct, Version 4 (10/2022)
CODE OF CONDUCT
Our values – Community, Innovation, Creativity, Sustainability, Quality Awareness and Cost
Effectiveness – are the guiding principles at the heart of everything we do. Through this code of
conduct, we are committing ourselves to acting responsibly and in an appropriate manner. In
this way, our employees will be better equipped to make business decisions and take action as
autonomous individuals.
Our employees are crucial to the success of our company because they are the bedrock of our
reputation and of the trust that our customers place in us. It is precisely for this reason that
clear ethical and moral principles need to be built into our business approach.
This code of conduct applies to all Fronius employees (white- and blue-collar employees,
apprentices, interns and leased staff) regardless of their position within the company. We also
expect our business partners to behave with integrity and in accordance with the law in line with
this code, throughout the entire supply chain.
Each and every employee is individually responsible for complying with and implementing the
code of conduct. Managers are required to set a good example for employees by putting the
code of conduct into practice themselves. They must also instruct their employees so that they
know how to respond to the code of conduct, must check that their employees are actually
following it and – with assistance from the compliance department– provide them with training.
When interpreting the rules of the code of conduct, employees must also rely on their own
judgement and must ask themselves whether a particular course of action is ethically or morally
questionable or could potentially provoke criticism. However, in those cases where legal
regulations apply, there is absolutely no room for personal discretion.
If employees have any questions or doubts about the code of conduct, they are welcome to seek
clarification from their line managers and the compliance department at any time. The
compliance department is also the ultimate authority for settling controversies or questions of
interpretation, and its interpretation shall be binding.
The compliance department can be contacted via the following e-mail address:
compliance@fronius.com
Gender-specific formulations refer equally to the female and male form.
Specified in Controlled Document for this pdf: CS-000007_Code of conduct, Version 4 (10/2022)
1. LEGISLATION/OTHER REGULATIONS
Die Einhaltung der geltenden Gesetze sowie der internen und externen Vorschriften ist die
Grundlage aller unserer unternehmerischen Aktivitäten und Entscheidungen.
2. FREE/FAIR COMPETITION
Professional, fair and transparent conduct in the marketplace is conducive to safeguarding our
interests in the long term and helps Fronius to securely maintain its competitiveness in a
sustainable way.
− When participating in the market, we steer clear of underhand marketing arrangements,
market abuse or concentrations of power. We avoid any restriction of free competition
and any breach of competition and antitrust laws. We respond to the challenges on the
market by ensuring that our employees are qualified and motivated, that our processes
are efficient and that our products are of high quality.
− In our dealings with our competitors, the following are strictly prohibited: arrangements
of any kind relating to prices or production quantities; discrimination against other
market participants; splitting or dividing up the market by apportioning customers,
suppliers, territories or business areas; exerting unreasonable pressure on business
partners; sham offers and similar agreements with other competitors; collusive
tendering; and any exchange of confidential information belonging to other market
participants, including, in particular, price calculations, production capacities, production
costs, terms and conditions of sale.
− We do not exchange information on sales offers with other market participants,
competitors, or customers. Sales offers from our competitors are neither examined nor
accepted for information. Likewise, our own sales offers are not disclosed and requests
from other market participants or competitors for further offers to customers are firmly
rejected.
− In our conduct towards our customers and dealers, specifications of fixed or minimum
prices for the resale of our products are prohibited. Any statement on sales prices must
be declared as a non-binding price recommendation and must be lived as such.
− By passive sales we mean, when we do not solicit the sale but a request for quote is
issued to us without our active involvement or sales measures. Passive sales are always
allowed! Internet sales are also fundamentally understood as passive sales. Far be it
from us to restrict or prohibit passive sales and internet sales of our competitors as well
as dealers and customers in any way or to exert pressure or threaten consequences
because of such sales activities.
Specified in Controlled Document for this pdf: CS-000007_Code of conduct, Version 4 (10/2022)
− We do not discuss any internal matters with our competitors that could affect market
behaviour, particularly prices and terms and conditions of sale, costs and calculations,
stock lists and capacities, production schedules, strategic information of any kind, and
confidential or protected information.
− In cases where we receive such unsolicited information from third parties, this is to be
documented and reported to the compliance department. Prompt notification shall be
made particularly if an inquiry or request is received from dealers with respect to sham
bids or bid rigging.
− We are sincere in our dealings with our suppliers and treat them fairly. We make
purchasing decisions purely on the basis of quality, deadlines and prices.
− Our cooperation in associations and lobby groups is geared towards positive economic
development. All political participation takes place responsibly and transparently.
Political processes are not hindered by unfair behavior or undue influence. All
participation in and activities associated with such associations are subject to the above
stipulations; In any case, it is forbidden to exchange market and price-related
information or to exchange confidential company information.
− Whenever conduct in breach of competition law is identified, it must be reported to the
compliance department immediately.
3. CORRUPTION/BRIBERY/MONEY LAUNDERING
We reject corruption in any form. Corruption is the abuse of one's power for one's own personal
gain or benefit. When accepting or granting benefits, we always take care to ensure that they
are appropriate and do not reflect badly on us in any way, irrespective of whether or not there is
a criminal dimension involved.
Appropriate action must be taken to counter even the slightest hint of unacceptable or dubious
conduct. For this reason, all our employees are forbidden from granting or accepting benefits of
any kind, particularly in cases where this could unduly affect business activities.
We do not tolerate any form of bribery. The granting or acceptance of gifts of any kind that give
rise to obligations or expectations is alien to us and will not be tolerated.
By “gifts” we mean any form of advantage bestowed, in particular invitations or other benefits
such as cash payments, vouchers/coupons, savings/reductions or intangible benefits. This does
not include gifts of minimal value, hospitality that is provided as part of normal business
practice, donations to people in need and sponsoring activities that are carried out with
sufficient transparency.
Specified in Controlled Document for this pdf: CS-000007_Code of conduct, Version 4 (10/2022)
Money laundering is the process of feeding sums of money or assets obtained by illegal means
into the legal financial and business markets. The money mainly originates from prohibited
activities such as tax evasion, bribery, blackmail, corruption, robbery, drug trafficking or the
illegal arms trade. The purpose of the “laundering” process is to conceal these origins.
We are committed to compliance with all applicable anti-money laundering regulations. No
flows of money are to be accepted if they could potentially be associated with money
laundering. In cases of doubt, careful scrutiny is required.
4. INTEGRITY/RESPECT
Every human being is precious and unique. We value and foster the abilities of each individual.
Our self-image and our code of conduct compel us to honour the dignity and personhood of
each employee, to deal with one another respectfully and to have due and deliberate regard for
diversity in a way that creates value.
Discrimination of any kind whatsoever will not be tolerated. This includes any form of
discrimination on the basis of a person's views and beliefs; on cultural, religious or political
grounds; on the basis of differing sexual orientations; and on the basis of differing mental or
physical characteristics or abilities.
Similarly, under no circumstances will we tolerate any kind of sexual harassment. This also
includes insinuating remarks or innuendos, whether made verbally or in writing, degrading
expressions or comments of a similar kind or pictures and images of a similar kind.
Any form of human trafficking, child labour or forced labour is strictly prohibited and is not
acceptable to Fronius even if only evident to a rudimentary extent.
5. CONFLICTS OF INTEREST
We make our decisions objectively and impartially based on the facts. If employees enter
situations where their own personal or economic interests come into conflict – or could
potentially come into conflict – with the interests of Fronius, we expect them to act solely in the
interest of the company. Every employee is required to fully disclose any current or potential
conflicts of interest to their direct line manager immediately and unprompted, and – if necessary
– to request special permission, even in cases where only a perceived conflict of interest of this
kind might arise.
Outside employment always requires prior written permission from the employee's direct line
manager and the HR department must also be informed. This also applies to participation in the
supervisory or advisory boards of companies outside of the Fronius Group.
Specified in Controlled Document for this pdf: CS-000007_Code of conduct, Version 4 (10/2022)
Economic involvement with competitors or business partners of Fronius (customers or suppliers)
is forbidden. The only exceptions to this are minor shareholdings in listed companies, provided
that these are in line with standard investment management practices. Managers must also
make their direct line managers and the compliance department aware – in a verifiable manner
– of any shareholdings that their close family members have in competitors or business partners
of Fronius.
Transactions with business partners must be reported to the employee's direct line manager
well in advance of any contract negotiations in cases where close family members of the
employee are involved in the corporate decisions of the business partner or are acting directly
as negotiators on behalf of the business partner.
If employees have close family members working in the same department as themselves, they
must disclose this to their direct line managers in a verifiable manner. By “close family
members”, we mean spouses, partners, parents, siblings and children.
6. HEALTH / ENVIRONMENT
We undertake to take responsibility for the health and safety of our colleagues and employees.
Unfair, exploitative and abusive work practices are checked and avoided with due care both in
our own organization and at suppliers and sub-suppliers.
We take responsibility for our environment and living spaces, in particular by avoiding
disproportionate environmental pollution and by promoting environmentally friendly
technologies.
We undertake to withdraw products in the distribution chain if they pose an unforeseen risk to
health, safety, or the environment. Taking into account their entire life cycle, our services and
products are designed to be as socially and environmentally compatible as possible.
7. HANDLING OF COMPANY INFORMATION/NON-DISCLOSURE
Confidential information of any kind (financial data, contracts, correspondence, technical data)
that is obtained in a professional capacity is intended exclusively for internal use and must not
be utilised to pursue personal interests. Nor is it to be disclosed to external third parties without
permission. Company information must always be kept safe and must be secured to prevent
access by third parties.
The strictest confidentiality must be observed in relation to all company and business secrets as
well as all matters relating to the company. Whenever the involvement of external partners is
sought, suitable non-disclosure agreements must be put in place.
Specified in Controlled Document for this pdf: CS-000007_Code of conduct, Version 4 (10/2022)
Employees remain bound by the non-disclosure obligation in full even after their employment
comes to an end. All employees are required to protect the intellectual property belonging to
Fronius and to prevent competitors or unauthorised third parties from accessing this exclusive
knowledge. Employees must treat the intellectual property of Fronius as strictly confidential and
use it exclusively for the purpose of carrying out their duties.
We respect the intellectual property of others. We will not tolerate any illegitimate use of
intellectual property that does not belong to us. We are aware of the highly sensitive nature of
any personal data entrusted to us and are committed to ensuring its protection by handling it
with care. This also applies to relevant data belonging to customers and suppliers.
8. REPORTING MISCONDUCT
All employees are required to comply with this code of conduct at all times. If employees identify
any breaches of the terms of the code of conduct, of other internal directives and rules or of
legal regulations, they must report them immediately. All such reports will be treated as
confidential and carefully investigated.
Employees are free to choose from the following reporting methods:
− Send the information to the compliance department (compliance@fronius.com
− Send the information to the Managing Director (GL@fronius.com
− Send the information to your direct line manager, or
− Reporting via the Fronius whistleblower reporting channel:
In this central, web-based whistleblower reporting channel, which can be used by both
employees and external whistleblowers, information as well as documents can be submitted
confidentially. The whistleblower reporting channel is intended to give employees the
opportunity to report violations both anonymously or through voluntary disclosure of one’s
identity. The channel and the associated policy with details on processing reports are available
at https://froniuswhistleblower.azurewebsites.net/?culture=de
In the interest of fostering open and trusting communication, we wish to stress explicitly that
any employees who do report identified breaches of laws, the code of conduct or other internal
directives and rules will not – under any circumstances – suffer any negative consequences
whatsoever as a result. Exactly the same applies to others who contribute important information
to the investigation of such misconduct.
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Specified in Controlled Document for this pdf: CS-000007_Code of conduct, Version 4 (10/2022)
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