Compliance

As a family-run business, Liebherr places great importance on behaving with integrity. In our view, this means above all behaving in a manner compliant with the applicable legislation, and furthermore also observing internal standards and adhering to a code of conduct. The Group understands the term compliance to entail not only combating corruption but also, in particular, adherence to the rules in relation to competition law and foreign trade law. To enable managers and staff to be in a position to behave with integrity and to conform with the legislation, we have drawn up various internal standards and codes of conduct. Furthermore, managers and staff are trained on so-called “Compliance Training” courses.

Liebherr standards of conduct

Standards of conduct for the area of foreign trade law

As an international Group, Liebherr supplies goods and provides services all over the world. Consequently, the Group is regularly confronted with laws and regulations from the area of foreign trade law (which we also consider the provisions of customs law to be part of).

Violations against the applicable laws and provisions of foreign trade law usually have far-reaching consequence for the companies involved and the individuals responsible for the violations.

Both in our own interest and in the interest of our customers and buyers, we therefore ensure that in our company the applicable national or intergovernmental rules and provisions of foreign trade law are observed and that appropriate processes and structures are maintained for this purpose.

Our standards of conduct

From our principles and code of conduct, the following standards of conduct for the applicable area can be derived:

Behaving with integrity is of great importance to us.
We respect the applicable legislative requirements in which we conduct business. This also includes the rules of foreign trade law.
In our company, we maintain relevant processes and structures that enable us to adhere to the rules of foreign trade law in an appropriate and economically viable manner.

Standards of conduct for hospitality and gifts

As a family-run business, Liebherr maintains regular and trusting contacts with customers and business partners, which have a long-term nature and require integrity with regard to behavior. Within the scope of maintaining these contacts, it is quite usual and acceptable to offer or accept company gifts and hospitality. However, these should never encourage anyone to conduct business or official matters in an unauthorized manner. In addition, it is important to ensure that the type and scope of the gifts and hospitality are commensurate with the situation in each individual case.

This ultimately also serves to prevent giving the impression that one is susceptible to such conduct or indeed corrupt. This approach should protect business partners and customers as well as staff of the Group against captious situations.

A conscious decision has been made to avoid setting fixed upper and lower limits. The standards of conduct are actually designed to encourage staff to act with a high level of caution and take personal responsibility in situations such as these. Individual companies of the Group are free to enforce locally stricter or more detailed regulations.

Our standards of conduct

From the principles and code of conduct of our company group, the following standards of conduct can be derived for the area of “hospitality and gifts”:

We do not bribe nor do we allow ourselves to be bribed.
We avoid conflicts of interest.
We avoid bringing ourselves and our business partners in captious situations.
We always orientate gifts and invitations around the occasion and group so that they are appropriate, and we avoid creating potential conflicts of interest.
We act with transparency in relation to gifts, gratuities and invitations.

Standards of conduct for dealing with sales partners

As a family-run business, Liebherr maintains a trusting relationship with its business partners, which is characterized by longevity and involves behaving with integrity. In return, Liebherr expects among other things integrity from its business partners as well as conformity with legislation.

This applies with greater importance to business partners who are directly involved with sales activities and who represent Liebherr and its business interests in dealings with third parties or advise the Group on specific projects or act in Liebherr's name when dealing with third parties.

On one hand, there is no way of ruling out that criminal or civil action could be taken against Liebherr for the sales partners' actions. On the other, it is about protecting the reputation of the Group.

Our standards of conduct

From our principles and code of conduct, the following standards of conduct for the way in which we deal with sales partners can be derived:

We maintain close relations with our sales partners, which are characterized by mutual respect and fairness.
We do not bribe nor do we allow ourselves to be bribed.
We avoid bringing ourselves and our sales partners (and their staff) in captious situations.
We employ transparent selection processes and actively seek to resolve doubt and ambiguity.
We treat information from our sales partners with confidentiality.
We support an approach (among our sales partners as well) that promotes competition and is in line with applicable directives and guidelines.
We expect that our sales partners do not use child or forced labor in their workshops and that they also do not discriminate according to age, gender, religion, disability or race.

Fair competition and monopolies law

As an international Group, Liebherr is obliged to observe the rules of fair competition in all markets. This is not least also in the interest of our customers who are at the heart of considerations and activities of the Group. Therefore, it is in our own interest to ensure that within the Group rules of open and fair competition are adhered to.

Violations against rules and regulations concerning competition law usually have far-reaching consequence for the companies involved and the individuals responsible for the violations.

Aside from significant fines and claims against the companies for compensation by the damaged party, there may also be incidences of personal liability and prosecution against any persons violating the rules. Violations against competition law also draw a lot of attention, which can lead to a considerable amount of damage to a company's reputation.

Our standards of conduct

From our principles and code of conduct, the following standards of conduct can be derived for the area in question:

We are committed to fair competition in the markets throughout the world.
Behaving with integrity is of great importance to us.
We respect brands, products and trade secrets from third parties.
We avoid untruthful or purposely misleading descriptions about products and performances.
We avoid entering into agreements that infringe on monopolies law or acting in a pre-arranged manner with third parties.

Selection and monitoring of suppliers and sub-contractors

This applies in particular to suppliers who are directly involved in the Liebherr supply chain as well as to sub-contractors with whom the Group has a direct contractual relationship.

The reason why Liebherr has to afford greater attention to the integrity and law-abiding nature of its suppliers and sub-contractors is, among other things, owing to the fact that possible violations by suppliers and sub-contractors can affect the Group directly or indirectly (damage to reputation, interruption in supply, etc.).

This guideline covers the aspect of selection and the active supervision of suppliers and sub-contractors purely in matters relating to compliance. It therefore does not replace existing or future, central or local procurement guidelines and/or processes. Individual companies are free to enforce locally stricter or more detailed regulations.

Our standards of conduct

From our principles and code of conduct, the following standards of conduct can be derived for the area in question:

We maintain close relations with our suppliers and sub-contractors, which are characterized by mutual respect and fairness.
We do not bribe nor do we allow ourselves to be bribed.
We avoid bringing ourselves and our suppliers and sub-contractors (and their staff) in captious situations.
We employ transparent selection processes and actively seek to resolve doubt and ambiguity.
We treat information from our suppliers and sub-contractors with confidentiality.
We support an approach (among our suppliers and sub-contractors as well) that promotes competition and is in line with applicable directives and guidelines.
We expect that our suppliers and sub-contractors do not use child or forced labor in their workshops and that they also do not discriminate according to age, gender, religion, disability or race.