Only to serve the easier legability the General Business Principles of AIM Infrarot-Module GmbH are written in male gender but refer to all genders equally.
AIM always conducts its business both in accordance with the principles described here as well as the applicable laws and official regulations of the countries in which the employees operate.
We do not only want to further expand our technological leadership. It is also our commitment to continously improve our relations with each other, with our customers and with our business partners. We also want to meet our social responsibility in an exemplary manner.
That in itself is a matter of course and we expect it to be a matter of course for you as well. In order to rule out any misunderstandings the management has adopted this Code of Conduct, which must be observed by all employees at all hierarchical levels, without exception, both internally and externally. We stand for fair competition. Unfair or even illegal practices are not compatible with our Code of Conduct. In particular, all forms of bribery and corruption are prohibited.
The same ethics and compliance requirements are of course also expected from our business partners.
We value a working environment in which our employees openly address compliance issues not only in cases of doubt, but also discuss them both with their supervisor and with the compliance organization. Our goal is to ensure that all employees are sensibilized to compliance in their day-to-day work through sustained communication and not only observe compliance requirements, but also actively demand integrity from colleagues and business partners.
Executive Board AIM Infrarot-Module GmbH
AIM is commited to integrity and fairness in all business activities and complies with all laws and regulations applicable to its business, including the local laws and regulations of all countries outside Germany in which operations are managed or services are provided.
AIM complies with the anti-corruption laws, directives and regulations that govern operations in the countries in which AIM does business, regardless of any local customs. This also includes compliance with anti-corruption laws with extraterritorial application.
AIM forbids every kind of bribery and corruption. No employee may offer, provide or accept bribes. Bribery is a criminal offense. This includes bribery in business transactions as well as bribery of any holder of office or granting of advantages and facilitation payments. In particular, any direct or indirect offer, promise, provision or acceptance of inappropriate benefits, whether material or of any other kind, for the purpose of acquiring orders or procuring unlawful advantages is forbidden to all employees (corruption).
AIM conducts reasonable due diligence to prevent and detect bribery and corruption in all business arrangements, including partnerships, the engagement of contractors and sub-contractors, joint ventures, offset agreements and the assignment of third-party intermediaries such as sales agents or consultants.
AIM does not offer any illegal payments to, or agrees to receive any illegal payments from any customer, supplier, their agents, representatives or others. AIM prohibits its employees from receiving, paying and/or promising sums of money or anything of value, directly or indirectly, intended to exert undue influence or improper advantage. This prohibition applies even in locations where such activity may not violate local law.
AIM does not offer, promise, make, accept or agrees to accept any improper payments of money or anything of value to government officials, political parties, candidates for public office or any other persons. This includes a prohibition on so-called "facilitation" or "grease" payments intended to expedite or secure performance of a routine governmental action, like obtaining a visa or customs clearance, unless there is a formal legal governmental fee schedule for such expediting services and the Government provides receipts. Personal safety payments are permitted where there is an imminent threat to health or safety.
Relationships with other companies and between employees and their business partners – e.g. with suppliers and customers and with governmental offices and their employees, etc. – must be characterized by transparency, especially in the areas of purchasing and sales.
This also applies to relationships with former employees and, in particular, to the family members of employees who directly or indirectly supply goods or services to AIM.
Employees who are involved in contractual negotiations with authorities must be familiar with the guidelines governing the process of submitting business offers in each respective country and may not violate them.
AIM competes for orders by fair and legal means and carries out contractual negotiations in compliance with all legal provisions.
AIM does not seek to gain an advantage of any kind by acting fraudulently, deceiving people, making false claims or allowing anyone else representing AIM to do so. This includes defrauding or stealing and any kind of misappropriation of property or information.
AIM does not enter into any formal or informal anti-competitive agreements that fix prices, manipulate supply, limit supply or allocate/control markets. AIM does not exchange current, recent or future pricing information with competitors. AIM does not participate in a cartel or any activity that would unlawfully restrain or affect competition.
AIM competes on the merits of its products and services. AIM does not use the exchange of business courtesies to gain an unfair competitive advantage. In any business relationship AIM ensures that the offering or receipt of any gift or business courtesy is permitted by applicable laws and regulations and that such exchanges do not violate the rules and standards of the recipient's organization and are consistent with reasonable marketplace customs and practices. No cash gifts or cash equivalents will be offered or accepted.
Gifts and other benefits may be accepted or granted only after approval by the respective company superior and/or the compliance officer and only under the condition that the gifts or benefits do not contravene laws or guidelines, are within proper limits and are not intended to influence decisions in a dishonest manner. The question of whether gifts or invitations are appropriate is to be decided according to normal business practices and with due consideration, if necessary, for the special customs of each individual country. Every appearance of dishonesty and incorrect behavior is to be avoided.
A conflict of interest may arise when an employee takes actions or pursues interests which may hamper him or her in objectivity and effectively carrying out his or her duties and meeting his or her responsibility to AIM or its business partners.
AIM and its employees avoid all conflicts of interest or situations that could pose of a potential conflict of interest. AIM will provide immediate notification to all affected parties in the event that an actual or potential conflict of interest arises. This includes a conflict between the interests of AIM and/or its business partners and personal interests or those of close relatives, friends or associates.
AIM ensures that its business practices are in accordance with all applicable laws, directives and regulations governing the import of goods, parts, components, technical data and services.
Employees involved in the import of goods, services or technical information must know and observe the relevant regulations. Furthermore, they have to ensure that the import documents are complete. Regular training courses and their repetitions are held for this purpose.
AIM ensures that its business practices are in accordance with all applicable laws, directives and regulations, including economic sanctions and embargoes, governing the export and transfer of parts, components and technical data and services. AIM provides truthful and accurate information and obtains export licences and/or permissions where necessary.
Employees involved in the export of goods, services or technical information must know and observe the relevant regulations. Furthermore, they have to ensure that the export documents are complete. Regular training courses and their repetitions are held for this purpose.
AIM complies with applicable laws and regulations regarding the direct and indirect sourcing of critical material and conflict minerals (i.e. when integrated in purchased products). Those materials include "conflict minerals" (tin, tungsten, tantalum, and gold), rare earth elements as well as other minerals or metals (e.g. bauxite, cobalt, titanium, lithium). AIM has established a policy and a management system to reasonably assure that the "conflict minerals" as well as critical material, which may be contained in products delivered by AIM, are sourced responsibly (i.e. with limited environmental impact and not detrimental to Human Rights).
AIM supports efforts to eradicate the use of any conflict minerals which directly or indirectly finance or benefit armed groups that are perpetrators of serious human rights abuses. AIM conducts due diligence and provides with supporting data on its sources and supply chain of custody for these minerals when requested and identifies any potential doubt on the origin and/or on the production means.
In the event that the material "chain of custody" supplied is "indeterminable" or otherwise unknown AIM either attains the appropriate certifications or phases out that source of mineral.
AIM develops, implements, and maintains effective methods and processes appropriate to its products to minimize the risk of counterfeit parts and materials being delivered. There are effective processes in place to detect, report and quarantine counterfeit parts and materials and to prevent such parts from re-entering the supply chain. If counterfeit parts and/or materials are detected or suspected, AIM provides immediate notification to the recipient of such counterfeit parts and/or minerals.
AIM complies with all laws and regulations applicable to its business on product safety and quality whilst delivering products and/or services to agreed product safety and quality standards.
AIM maintains quality assurance processes to identify any defects and implements corrective actions.
AIM complies with the legal regulations on money laundering prevention.
AIM operates appropriate controls to accurately and securely create, store and maintain business records and does not alter any record entry to conceal or misrepresent the underlying transaction. All records, regardless of format, made or received as evidence of a business transaction fully and accurately represent the transaction or event being documented. Records are retained based on the applicable retention requirements.
AIM ensures that all sensitive, confidential and proprietary information is appropriately protected.
AIM complies with applicable data privacy laws on the collection, processing and transfer of personal data and information.
AIM does not use information for any purpose (e.g. advertisement, publicity, and the like) other than the business purpose for which it was provided, unless there is prior authorization from the owner of the information.
AIM protects the sensitive, confidential and proprietary information of others, including personal data/information, from unauthorized access, destruction, use, modification and disclosure, through appropriate physical and electronic security procedures, including mitigating emerging risk to information systems by implementing appropriate IT cyber security programs.
AIM reports any suspected or actual breach or security incident as soon it is aware to the entity they do business with, if the data breach / security incident affects the business relationship.
Every employee is obliged to treat business information not publicly accessible about AIM or its business partners with the strictest confidentiality and to protect it from unintentional disclosure.
One of AIM’s most significant assets is its intellectual property. This includes patents, business secrets, trademark rights and copyrights. It is AIM’s business policy to exercise all rights to economically significant intellectual property and to use, maintain, protect and defend them in a responsible manner.
AIM complies with all applicable laws governing intellectual property rights assertions, including protection against disclosure. Moreover, AIM respects the intellectual property of other natural persons and legal entities and uses the relevant information, computer programs or processes only in accordance with the respective license agreements or within the framework of the legal provisions.
AIM and its personnel do not use any material or non-publicly disclosed information obtained in the course of their business relationship as the basis for trading or for enabling others to trade in the stock or securities of any company.
AIM ensures it complies with all applicable tax laws and regulations in the states where it operates and is open and transparent with the tax authorities. Under no circumstances, AIM engages in deliberate illegal tax evasion or facilitates such evasion on behalf of others.
Thus AIM maintains effective controls to minimize the risk of tax evasion or its facilitation, and provides appropriate training, support and whistleblowing procedures to ensure its employees understand and implement them effectively and can report any concerns.
AIM is fair and reasonable in its payment practices and pays undisputed and valid invoices on time in accordance with agreed contractual payment terms.
AIM actively manages risks in accordance with applicable legal regulations and does not pass down risks inappropriately to subcontractors or third parties. AIM shares information on risks to ensure risks can be mitigated.
Based on the UN Guiding Principles on Business and Human Rights and the four fundamental principles of the ILO core labor standards, AIM conducts its business and operations in a way that respects human rights by treating its own employees and people working for its suppliers with dignity and promoting fair employment practices. This includes providing fair and competitive wages, prohibiting harassment, bullying and discrimination, prohibiting use of child, forced, bonded or indentured labor and not engaging in trafficking of persons for any purpose.
AIM identifies risks and actual adverse human rights impacts related to its activities and business relationships and informs the responsible persons and the management about this as part of internal risk management. AIM takes appropriate steps to identify, prevent, reduce risk and ensure its operations do not contribute to human rights abuses and to remedy any adverse impacts directly caused, or contributed to, by its activities or business relationships.
AIM ensures that illegal child labor within the meaning of Nos. 138 and 182 of the International Labor Organization (ILO) Convention is not used in the performance of work. The term “child” refers to any person under the minimum legal age for employment where the work is performed and/or the minimum working age defined by the ILO, whichever is higher.
All employees under the age of 18 are protected from performing work that is likely to be hazardous or that may be harmful to their health, physical, mental, social, spiritual, or moral development.
AIM prevents any involvement in all forms of modern slavery of any kind, including trafficking in persons (especially trafficking of women and children), forced, bonded or indentured labor. All work is involuntary on the part of the employee.
AIM provides all employees with a written contract in a language they understand clearly indicating their rights and responsibilities with regard to wages, working hours, benefits and other working and employment conditions. AIM does not retain any form of employee identification (passports or work permits) nor destroys or denies access to such documentation as a condition of employment unless required by applicable law.
AIM does not charge employees fees, recruitment costs or deposits, directly or indirectly, as a precondition of work.
AIM respects the right of workers to terminate their employment after reasonable notice and to receive all owed salary. AIM respects the right of workers to leave the workplace after their shift (see also Wage, Benefits and Working Hours).
Cultural differences are accepted and respected. Therefore AIM fosters a diverse and inclusive work environment where employees are treated with respect and fairness.
AIM provides equal employment opportunity to employees and applicants for employment without discrimination and complies with all non-discrimination laws and regulations.
AIM ensures that employment, including hiring, payment, benefits, advancement, termination and retirement, is based on ability and not any personal characteristics.
AIM ensures that its employees are afforded an employment environment that is free from physical, psychological, sexual and verbal harassment, intimidation or other abusive conduct.
AIM pays workers at least the minimum compensation required by local law and provides all legally mandated benefits. In addition to payment for regular hours of work, workers are paid for approved overtime necessary for operational reasons and at such premium rate as is legally required or, in those countries where such laws do not exist, at least equal to their regular hourly payment rate. AIM does not permit deduction from wages as a disciplinary measure nor permits any other deductions, which are not provided by national law.
AIM provides employees with regulated hours of work, daily and weekly rest periods and annual leave.
AIM respects the occupational health and safety obligations applicable and has an appropriate safety management system including policies focussed on protecting the health, safety and welfare of employees, contractors, visitors and others who may be affected by its activities by striving to eliminate fatalities, work-related injuries, health impairment and limiting exposure to safety hazards.
AIM takes reasonable steps to provide a hygienic working environment and ensures that employee's performance and safety is not impaired by alcohol, controlled substances, legal and illegal drugs.
AIM respects the rights of workers to associate freely and communicate openly with the supervisor or with the management regarding working conditions without fear of harassment, intimidation, penalty, interference or reprisal.
AIM recognizes and respects any rights of workers to exercise lawful rights of free association, including joining or not joining any association of their choosing within the appropriate national legal framework. AIM recognizes that unions may operate freely and in accordance with the law of the employee's location; this includes the right to strike and the right to collective bargaining.
AIM has an employee disciplinary process in place to address concerns regarding employee work, conduct or absence.
AIM has a grievance mechanism for employees to raise a workplace problem or concern or to appeal a disciplinary decision.
The above procedures comply with the relevant legal requirements.
AIM recognizes the property of third parties and rejects unlawful evictions and the unlawful deprivation of land, forests and waters associated with the acquisition, development or other use of land, forests and waters, the use of which secures a person's basis of existence.
AIM values a sustainable and responsible approach to the environment as well as natural resources. Therefore, in the course of its business activities, AIM strives to continuously improve the environmental performance of its locations, products and services and actively manages environmental risks across its operations, products and supply chain.
AIM has established an appropriate environment management system at its locations, including directives and procedures aimed at ensuring compliance with laws, regulations and other binding obligations in order to improve environmental performance and to protect the environment from harmful effects. In doing so, AIM is focused at a continuous reduction of consumption of energy, water and natural resources and ensures a legally compliant handling of waste, waste water and hazardous substances. AIM minimizes hazardous waste, ships goods in appropriate repackaging and promotes reusable / recycled packaging materials, and responsibly manages its air emissions.
Furthermore AIM incorporates environmental aspects into its own product development and service. AIM is committed to environmentally compatible, advanced and efficient technologies and implements them over the entire life cycle of its products.
AIM prepares and publishes sustainability reports in accordance with the applicable legal requirements.
AIM implements and adheres to this Code of Conduct and operates an effective compliance program and requires its employees to make ethical, value-based decisions in doing business.
Superiors and managers have a special role model function and ensure that their employees are familiar with the content of this Code of Conduct. The managers implement preventive measures in their area in order to prevent violations. All employees at all hierarchical levels, as well as the executive bodies, are themselves responsible for compliance with this Code of Conduct. Notwithstanding any further civil and/or criminal consequences violations can be punished with disciplinary measures.
Compliance training courses (on-site events and e-learning) on the requirements of this Code of Conduct are held regularly for employees at all hierarchical levels.
In order to anchor compliance at AIM and to enforce the Code of Conduct, the executive board has established a compliance organization which regularly reports to the executive board. The compliance organization reviews our business processes with regard to compliance with these principles and is point of contact for business partners and employees concerning any compliance related subjects.
AIM encourages its employees to report suspicious cases in order to prevent damage to the company. The identity of employees who report a possible violation will be treated confidentially. Similarly, no employee may be sanctioned or otherwise disadvantaged as a result of having made such a report.
The AIM compliance organization has contact persons which employees can contact directly.
In addition, AIM offers its employees other appropriate reporting channels, including the option of anonymous reporting via a whistleblower system. An ombudsman is also available as a contact person.
AIM also requires its suppliers to comply to the same ethics and compliance requirements.