Corporate behaviour including anti-corruption and anti-competitive behaviour
Our approach
Our Group’s reputation is built on our tradition of high integrity, good business conduct, dedication, and the unbiased excellence of the people who work here and who are fundamental to our achievements. Exhibiting responsible corporate behaviour is key in order to ensure our future economic success on a sustainable basis. By applying high standards of business ethics and fostering integrity and credibility, we can positively influence our inter-actions with stakeholders, such as our customers and suppliers, thus preserving our reputation.
With our company-wide policies, such as the “Code of Business Conduct”, the “Health, Safety, Environmental and Sustainability Policy” and the “Corporate Social Responsibility Policy”, Jungbunzlauer’s management takes its responsibility for ensuring good business practices seriously. These policies are shared with all employees – including all members of the governance bodies – during their introductory training and are available on our intranet. In case of questions or for advice regarding the implementation of our policies and practices, employees can directly contact their direct supervisor, the HR department or the top management of the relevant entity, or our Management Committee. There is also a whistleblowing system in place, which can be used in case of concerns.
For our suppliers, we have a specific “Supplier Code of Conduct”, which is shared with every relevant supplier. More details on this can be found in chapter 3.2 in our report.

Code of Conduct
The Jungbunzlauer “Code of Business Conduct”, which was updated in 2022, provides practical and easy-to-understand explanations of many of the basic rules and principles that apply to our businesses. Two of the most relevant material
topics for our stakeholders – anti-corruption and anti-bribery – are addressed, together with the topics of anti-competitive behaviour, antitrust and fraud, conflicts of interest, and whistleblowing.
The Code applies to the Jungbunzlauer Group and all of its subsidiaries, branches and representative offices worldwide and covers members of the Board of Directors, executives, officers and employees, regardless of location. The management team of each Jungbunzlauer company is responsible for observing the guidelines in our policies and ensuring that their employees understand and comply with the Code. Depending on local regulations, different Jungbunzlauer entities may have their own guidelines and/or policies in addition to those mentioned in the Code.
Corporate Social Responsibility Policy
This policy focuses on Jungbunzlauer’s responsibility towards its stakeholders regarding health and safety conditions, business practices and the safety of our products. It is reviewed and updated every five years by the Management Committee. Observance of this policy is the responsibility of the management of each Jungbunzlauer subsidiary. The companies’ managers and executive boards immediately report any arising problems or non-compliance to the CEO. Our “Corporate Social Responsibility Policy” is also applicable in the workplace.
Compliance training
Compliance training events help us to overcome legal and ethical challenges, provide orientation, and strengthen confidence in our performance and integrity.
Upon starting work at Jungbunzlauer, an online compliance training course must be completed by all commercial employees (Sales, Product Management), employees from Administration and Management and Operations, as well as by members of the Management Committee and Board of Directors. Since 2021, all relevant employees, including members of the Management Committee, have been required to undergo refresher compliance training every two years.
Our training covers the following topics: information security, compliance basics, preventing corruption, fair competition, data protection, and responsible exporting. In 2023, a new training section about whistleblowing will be added.
Our ambition
The Jungbunzlauer Group is active in all relevant markets throughout the world, so compliance with different laws and regulations is essential for our business activities. Following the Jungbunzlauer “Code of Business Conduct” guarantees that our reputation is maintained.
Key measures and evaluation
Online compliance trainings
Targets 2022
Continued online compliance training for all relevant employees, including management
Progress and achievements 2022
In 2022, 97% of employees completed the compliance training assigned to them. All commercial employees and employees from administration and operations participated
"Code of Business Conduct"
Targets 2022
- Zero cases of corruption
- Zero incidents of unethical business conducta
Progress and achievements 2022
- Zero confirmed incidents of corruption were recorded in 2022
- Zero confirmed incidents of unethical business conduct were recorded in 2022
"Corporate Social Responsibility Policy"
Targets 2022
Review
Progress and achievements 2022
General update and updated reference to the “Health, Safety, Environ metal and Sustainability Policy”
Export control procedure
Targets 2022
Continued training of employees on new export control procedure implemented in 2019
Compliance with relevant export control laws
Avoidance of infringements of export control laws
Creation of uniform standards
Progress and achievements 2022
- A completion rate of 95% (of relevant employees) was reached for export control training in 2022
- Procedural information and instructions now available for all Jungbunzlauer locations, defining responsibilities within the different locations
Whistle blowing system
Targets 2022
Monitoring of whistle blowing procedure
Progress and achievements 2022
- In 2022, one case of misconduct was reported via our external whistleblowing hotline. After a thorough investigation by a third party, the allegations were confirmed.
- Disciplinary action was takenb
a Anti-competitive behaviour and violations of antitrust and monopoly regulations
b This incident was previously reported in our 2021 Sustainability Report, although the incident actually occurred in 2022
Outlook
In order to maintain our high standards in business practices, compliance training will continue every two years for all relevant staff.
To prevent liability risks, internal and external audits regarding export control will be carried out on a regular basis. Implementaion is planned for 2024.
