d.velop Code of Conduct
1. Principles and Objectives
Founded in 1992, d.velop AG, together with its subsidiaries, forms the d.velop Group. The parent company of d.velop AG is d.velop holding GmbH. The members of the d.velop Group develop and market modular Enterprise Content Management (ECM) applications and solutions that optimise document-based business and decision-making processes in companies and organisations – either on-premises or in the cloud.
We are fully aware of our societal responsibility.
Corporate sustainability begins with living a value system and practising responsible corporate governance.
The public image of our organisation is significantly shaped by the conduct and demeanour of every single employee as well as the corporate management. This means that both the management bodies of the d.velop Group companies and each employee are responsible for ensuring that their actions and omissions support and enhance – rather than harm – our environmentally and socially conscious reputation.
These codes of conduct and core values are binding rules that apply to all employees and all members of corporate management, including the Management Board, managing directors, authorised signatories, and senior managers. They take precedence over all other guidelines and policies and are to be used as interpretative guidance if other documents contain ambiguities or gaps.
These codes and values support us in addressing ethical and legal challenges in our daily work. Any employee may contact their supervisor or corporate management with questions or concerns relating to these principles at any time.
We explicitly acknowledge the core principles of the EU Directive on Corporate Social Responsibility as well as the ten principles of the United Nations Global Compact. These codes of conduct and values also follow the guidance of DIN ISO 26000, “Guidance on Social Responsibility.”
To simplify the text, the term “employee” is used as a gender-neutral designation for all staff members and external workers, regardless of gender or legal status.
2. General Standards of Conduct
2.1. Lawful Conduct
Compliance with the law is a top priority for all companies within the d.velop Group.
The d.velop Group takes its legal obligations very seriously.
Every employee and all members of management must observe the laws and internal regulations relevant to their work and act within these frameworks. Legal violations must be avoided under all circumstances, particularly those that may result in imprisonment, fines, or administrative penalties.
Any employee who breaches the law may face disciplinary and employment-related consequences in addition to any legal sanctions. For members of management, corporate and, where applicable, employment-related legal consequences may apply.
2.2. Responsibility for the Reputation of the d.velop Group
The reputation of the d.velop Group is significantly influenced by the conduct of each of us. Inappropriate behaviour by even a single employee can cause substantial harm to the company.
All employees and members of management are expected to uphold the reputation of the d.velop Group in all public settings. Their actions must reflect this responsibility in every respect – including their conduct online and in social media.
2.3. Mutual Respect, Honesty, and Integrity
We respect the personal dignity, privacy, and individual rights of each person. We work with people of different backgrounds, nationalities, cultures, religions, skin colours, and sexual identities. We do not tolerate discrimination, sexual harassment, or any other form of personal harassment or insult.
We are open, honest, and act with integrity. We accept responsibility and only make commitments we can honour.
These principles apply to both internal collaboration and interactions with external partners.
We ensure fair employment conditions, pay fair wages, and consider the needs of employees in business decisions.
2.4. Leadership, Responsibility, and Supervision
Every supervisor and member of management is responsible for the employees entrusted to them.
They must earn the respect of employees through exemplary personal conduct, performance, reliability, and social competence. Management sets clear, ambitious, and realistic goals, which are developed in participatory processes involving employees and supported by them. We lead through trust and allow employees as much personal responsibility and autonomy as possible. Supervisors, corporate management, and HR are available to support employees – professionally and personally.
All supervisors and members of management have organisational and supervisory duties. They are collectively responsible for ensuring that no legal violations occur in their area of responsibility that could have been prevented or made more difficult through proper oversight. Delegating tasks does not release them from this responsibility.
Specifically, leadership, responsibility, and supervision entail:
- Duty of Selection: Supervisors must carefully select employees based on personal and professional qualifications. The greater the significance of a task, the higher the required diligence.
- Duty of Instruction: Supervisors must assign tasks clearly, completely, and bindingly – especially with regard to legal compliance.
- Duty of Monitoring: Supervisors must ensure ongoing monitoring of compliance with legal obligations.
- Duty of Consequence: Supervisors must clearly communicate that violations of law are unacceptable and will lead to employment-related consequences.
In cases of doubt, supervisors must consult with corporate management.
Interaction with Business Partners and Third Parties
3.1. Compliance with Competition and Antitrust Laws
Only fair and honest competition has the right to thrive. The principle of integrity also applies when competing for market share. All employees and members of management are obligated to comply with the rules of fair and honest competition.
In particular, employees and management must not enter into discussions with competitors about pricing or production capacities. Agreements on refraining from competition or on submitting sham bids in tenders are also prohibited.
We offer our suppliers fair and honest contract terms and appropriate compensation and we expect them, in turn, to treat their own employees and suppliers fairly, lawfully, and ethically.
3.2. Offering and Granting of Benefits
We compete for business through the quality and pricing of our innovative products and services. No employee or member of management may, in the context of business activity, directly or indirectly offer or grant any undue advantage—whether monetary or otherwise.
Gifts or complimentary services to employees of business partners must be selected to ensure that no appearance of impropriety arises. If in doubt, the recipient should be asked to obtain prior approval from their supervisor. If the recipient resists, it may indicate that they themselves consider the gift to be inappropriate.
Employees and managers who enter into contracts with consultants, agents, or similar third parties must ensure that these third parties also do not offer or grant any improper benefits.
3.3. Soliciting and Accepting Benefits
No employee or member of management may use their professional position to unlawfully solicit, accept, acquire, or be promised personal benefits.
The only exceptions are customary occasional or promotional gifts, hospitality, or other low-value benefits. A strict standard must be applied when assessing the appropriateness and value to avoid even the appearance of undue influence. In cases of doubt, prior approval from management must be obtained.
3.4. Special Rules for the Awarding of Contracts
Applicants expect fair and impartial evaluation of their bids. Employees and management involved in awarding contracts must comply with the following:
- Employees must immediately inform their supervisor of any personal interest that could conflict with legal obligations or this Code of Conduct.
- Members of management must inform their peers of any personal conflict of interest and, if necessary, assign the matter to another member of management.
Suppliers must not be unfairly favoured or disadvantaged in the bidding process.
Invitations from business partners may only be accepted if the occasion and scope are appropriate and rejecting the invitation would breach common courtesy.
Gifts from business partners are to be refused and returned—except for occasional or promotional gifts, hospitality, or other low-value tokens. A strict standard applies in assessing appropriateness to avoid any impression of bias.
Employees and members of management must not assign private work to companies they deal with professionally if such work could provide them with direct or indirect personal advantage.
3.5. Donations
The d.velop Group makes financial and in-kind donations to support education, science, art, culture, sport, and social causes. Requests for donations are received from various organisations, institutions, and associations.
The following rules apply to donations:
- Requests from individuals are to be declined.
- Payments to private bank accounts are not permitted.
- No donation may be made to individuals or organisations with questionable reputations or whose goals conflict with those of the d.velop Group.
- Donations must be transparent. The recipient and the intended use must be clearly documented. The purpose and allocation of funds must be accountable at all times.
- Donations should be tax-deductible.
4. Avoiding Conflicts of Interest
4.1. General Principle
The d.velop Group is committed to avoiding conflicts of interest or loyalty in the activities of its employees and managers. Such conflicts may arise, for instance, if an employee or executive is active in or holds shares in another company. For this reason, avoiding conflicts of interest is a guiding principle.
4.2. Non-Compete Obligation
Employees and managers may not operate a business that competes directly or indirectly with the d.velop Group without express written approval. This also applies to direct or indirect holdings in non-listed competitors.
Prior written approval is also required for investments in business partners of the d.velop Group. Such permission is issued in writing and filed in the employee’s personnel record. Executives require approval from the shareholders or supervisory board. The permission may be revoked if the individual is professionally involved with the respective company.
If a close relative of an employee has such a stake, the employee must report it in writing to HR, and it must be recorded. Executives must inform fellow board or management members.
4.3. Secondary Employment and Political Office
The d.velop Group supports political engagement in principle. However, paid secondary employment or assuming a political office must be reported in writing to management in advance.
Secondary employment may be prohibited if it impairs work performance, conflicts with company duties, or poses a risk of a conflict of interest. In the case of executives, the shareholders or supervisory board decide.
5. Use of Company Facilities and Information
5.1. Use of Company Resources
Company equipment (e.g. telephones, computers, mobile devices, software, internet/intranet) may be used only for business purposes unless otherwise agreed.
Under no circumstances may employees access or distribute content that promotes racial hatred, glorifies violence, or contains culturally offensive sexual content. Executives voluntarily commit to this principle.
Employees may not record or duplicate documents, images, or audio files without prior written approval unless such actions are directly work-related and legally permissible. This obligation also applies to executives.
5.2. Records and Reporting
Transparent and effective cooperation requires accurate and truthful reporting—internally, with customers and partners, the public, and authorities.
All internal and external records and reports must be complete and truthful. According to the German GoBD principles (tax record-keeping standards), data must always be accurate, complete, and timely.
This also applies to travel and expense claims.
5.3. Confidentiality
Employees must maintain confidentiality regarding all non-public internal matters. This includes organisational details, internal reporting figures, etc. The duty of confidentiality continues even after termination of employment.
6. Data Protection, Data Security, and IT Security
As an IT service provider, the d.velop Group is particularly committed to data protection, IT and information security, and the protection of personal rights. We comply with all relevant data protection laws, including telecommunications privacy regulations.
We commit to protecting the privacy, fundamental rights, and freedoms of data subjects as required by law. These principles are an integral part of IT management, leadership, and everyday conduct.
7. Environmental Responsibility
The d.velop Group takes clear responsibility for protecting the environment. Environmental aspects are assessed and considered in all company processes. We take preventive measures to reduce our environmental impact and comply with all applicable laws and regulations.
We operate an integrated management system (IMS) in accordance with:
- DIN EN ISO 14001:2015 for environmental management
- DIN EN ISO 50001:2018 for energy management
We commit to:
- Providing the necessary information and resources to meet our IMS goals
- Continuously improving the IMS
- Complying with all binding and applicable requirements
- Protecting the environment, including pollution prevention
- Improving environmental performance
- Procuring energy-efficient products and services that impact our energy performance
- Considering energy performance improvements in design activities
- Continuously enhancing our energy performance
8. Responsibility to Employees
8.1. General Responsibility
All employees are treated with dignity and respect. Discrimination based on race, religion, gender, marital status, maternity, age, political opinion, national origin, sexual orientation, or any legally protected characteristic is not tolerated.
Wages and working hours comply with legal requirements, including minimum wage laws. Terms regarding working hours, overtime, benefits, and notice periods are outlined in employment contracts or communicated through standard company policies.
All legally required benefits, especially healthcare and social security, are granted. We support collective bargaining rights and freedom of association.
The d.velop Group does not engage in employee leasing to third parties.
8.2. Occupational Safety
We take responsibility for employee health and safety in the workplace. We implement best-practice preventative measures to reduce risks and avoid accidents or occupational illness. We maintain a safety management system with regular training.
8.3. Complaints and Reporting
Employees have the right to report violations of this Code or suspected misconduct. They may contact their supervisor or management.
Employees acting in good faith will not face any disadvantage from reporting concerns. Protective measures will be taken as needed to prevent retaliation.
Where possible and legally permitted, d.velop Group will maintain the confidentiality of whistleblowers and those helping to clarify violations.
9. Implementation and Oversight
The d.velop Group actively promotes awareness of this Code of Conduct and Core Values. Members of management serve as role models and are measured by their adherence to these principles. They are the first point of contact for questions and ensure all employees understand the Code.
Management is responsible for preventing unacceptable behaviour and for taking steps to avoid violations in their area of responsibility.
Trust and cooperation are reflected in open communication, transparency, and mutual support between employees and leadership.
The Executive Board and Management of the d.velop Group