CODE OF CONDUCT
Compliance with applicable law
We comply with all applicable laws and regulations at the local, national and international level. These include in particular:
- Swiss law (OR, Criminal Code, revDSG)
- EU law (GDPR, AI Act, competition law, antitrust law)
- International standards (UN Guiding Principles on Business and Human Rights, OECD Guidelines, ILO Core Labour Standards)
- Industry standards (ISO 27001, ISO 9001, ISO 37301 Compliance Management)
All employees are required to know and comply with the laws, regulations, and internal policies relevant to their area of responsibility. Executives bear a special responsibility for ensuring compliance and acting as role models.
Fairer competition
We are committed to complying with all antitrust and competition law regulations. In particular, the following are prohibited:
- Price agreements
- Market or customer segmentation
- Anti-competitive boycotts
- Agreements with competitors, suppliers or distribution partners
- unfair business practices
We act fairly, transparently and in accordance with applicable competition law at all times.
Relations with business partners
We act with integrity, transparency, and in compliance with the law towards all business partners. We fulfill our contractual obligations and expect the same from our partners.
Business relationships are based on:
- Integrity
- Transparency
- Reliability
- Compliance with all legal and regulatory requirements
- Avoiding conflicts of interest
Confidentiality & Information Security
We protect confidential information from unauthorized disclosure, loss, or misuse. This includes:
- Business documents
- Contracts
- Financial data
- Personal information
- Intellectual property
- Technical documentation
- AI models and data structures
Confidential information must be kept secret – even after the employment relationship has ended. We implement technical and organizational measures in line with current standards (e.g., ISO 27001).
Data protection (GDPR + CH‑DSG)
We comply with all applicable data protection laws, in particular:
- Swiss Data Protection Act (revDSG)
- EU Data Protection Regulation (GDPR)
Personal data shall be processed lawfully, fairly, and transparently. Employees who work with personal data receive training and support from the data protection officers.
Protection against corruption and bribery
We condemn any form of corruption, bribery and the granting of advantages. This includes:
- Bribery of public officials
- Bribery in business dealings
- unsuitable gifts or invitations
- Hidden payments
- Kick-backs
- Granting benefits to influence
We adhere to international anti-corruption standards:
- Swiss Criminal Code
- EU anti-corruption policies
- UK Bribery Act
- US Foreign Corrupt Practices Act (FCPA)
Subsidies are only permitted if they:
- appropriate
- transparent
- business-like
- documented
- not intended as a reward for an advantage
Conflicts of interest
Employees must disclose actual or potential conflicts of interest, in particular:
- Personal relationships with business partners
- private economic interests
- Side activities
- Investments in competitors
Trust, Respect & Equal Treatment
We foster a work environment characterized by respect, fairness, and tolerance. We tolerate no discrimination based on:
- ethnic origin
- Nationality
- Gender
- Pregnancy or parenthood
- Family status
- Age
- Disability
- Religion or world view
- sexual orientation
- Identity
- political opinion
- social origin
Harassment, bullying and intimidation are prohibited.
Human rights, health & safety
We respect human rights in accordance with:
- UN guiding principles
- ILO core labor standards
- OECD Guidelines
- Swiss labor law
- EU occupational safety directives
We ensure a safe, healthy, and hazard-free working environment. Executives ensure that protective measures and safety processes are in place.
Environment & Sustainability
We are committed to sustainable and responsible business practices. This includes:
- efficient use of natural resources
- Minimizing environmental impacts
- Compliance with environmental regulations
- Consideration of CSRD/ESRS standards (EU)
- sustainable procurement
Supply chain due diligence obligations (LkSG / OECD)
We ensure compliance with human rights and environmental due diligence obligations along our supply chain. We expect our suppliers to:
- Compliance with international human rights standards
- No child or forced labor
- fair working conditions
- Environmental responsibility
- Transparency and cooperation
AI Ethics & AI Act Compliance
We develop and use AI systems responsibly and in accordance with the EU AI Act. Our AI principles:
- Transparency
- Fairness
- Non-discrimination
- Security
- Human supervision
- Documentation
- Monitoring
- Bias controls
AI systems are not used for automated decisions with legal effect.
Whistleblower system / Whistleblowing
We provide a secure, confidential whistleblowing system that meets international standards (EU Whistleblower Directive). Employees can report violations:
- anonymous
- Confidential
- without fear of reprisals
