Code of Conduct for Employees
“How We Work” is the Code of Conduct for all our employees, members of management and members of the Board of Directors. Scroll down to view our Code online.
Code of Conduct for External Business Partners
Our “Code of Conduct for External Business Partners” provides guidance on all our business relationships outside Implenia. Read it to find out about the requirements for a long-term, successful partnership with us.
Download the PDF “Code of Conduct for External Business Partners”
1. What we stand for
Our Values
WE DO
- We read our Code and Internal Rules, which are available in our Implenia Management System – our primary source of information – and take part in training courses.
- We speak up when we have questions or when we become aware of potential breaches of applicable laws, our Code or our Internal Rules.
- We act in a manner consistent with our company values.
- We cooperate fully when asked to take part in an investigation or audit.
Our Code cannot cover every topic, so if you are unsure whether your conduct complies with the principles of applicable laws, our Code or our Internal Rules, the first step is to ask yourself the following questions:
2. Our Integrity
Protecting the Company’s Interests
How do we remain loyal?
We always make business decisions objectively and fairly in the best interests of Implenia, and we do not allow our personal interests to prevent us (or even appear to prevent us) from doing so.
WE DO
- We understand that even the mere appearance of a conflict of interest can be damaging.
- We disclose any potential conflicts of interest to our line manager and to Compliance.
- We obtain prior written approval from our HR Business Partner before taking on secondary employment and comply with our Group Table of Responsibilities when considering whether to accept an external appointment (e.g. executive management, board of directors, board of trustees).
WE DON’T
- We do not acquire any ownership stake in a competitor or a third party that does business with Implenia.
- We neither supervise family members nor are we involved in their recruitment.
- We do not pursue business opportunities identified through our role at Implenia that could conflict with Implenia’s interests or our duties.
Give and Take
How do we deal with gifts and invitations?
We avoid even the appearance of corruption and bribery, and only accept gifts when they are appropriate and are not intended to unduly influence decision-making. We ensure that all gifts comply with the applicable value limits and are duly approved in accordance with our Global Integrity Directive. Gifts may include services, loans, travel, promises, favours – anything of value.
WE DO
- We review each gift and invitation and assess the frequency and timing of gifts we receive from the same supplier or partner, the value of the gift and the potential intent of the person giving the gift.
- We ensure that any gift or invitation we offer to a third party complies with their internal rules.
- We exercise caution when a government official is involved.
- We seek the necessary approval when considering sponsorship of, or contributions to, any organisation or individual.
- We report to Compliance any attempt by a third party to improperly influence us.
WE DON’T
- We do not accept gifts or invitations if the third party expects to either receive benefits of any kind or to unduly influence our decision-making.
- We do not accept gifts or invitations from external business partners at our home address.
- We do not make facilitation payments, or small payments intended to facilitate routine government actions, such as the issuing of permits.
- We do not exchange cash or cash equivalents, such as gift cards, with third parties.
Question
I am working on a project with a state-owned railway company, and an engineer who works for the railway company has asked to travel to Implenia’s head office for discussions. Should Implenia pay for the travel?
Answer
No. Employees of government-owned or government-controlled organisations may be regarded as government officials, and any gifts made to such officials must be pre-approved, as set out in our Global Integrity Directive..
Fair play in the market
How do we act fairly?
We champion free, fair and effective competition, and we refrain from taking any measures that restrict it or distort the market. When dealing with third parties, particularly customers and competitors, we neither discuss any agreements nor engage in any discussions regarding prices, quantities, territories or markets that restrict or distort the market.
WE DO
- We familiarise ourselves with the reasons for setting up a joint venture, follow due process and ensure that our reasons are properly documented when setting up or joining one.
- We always check the agenda before attending trade association meetings, conferences or meetings with competitors. Where competition-related topics are on the agenda, we request that they be removed or do not attend the meeting.
- We distance ourselves from any improper behaviour by competitors or suppliers, such as attempts to reach informal agreements on prices or other terms.
WE DON’T
- We do not discuss our business strategies unless they are in the public domain, and we never use terms that imply a restriction on free trade, such as ‘monopoly’ or ‘monopolist’.
- We do not influence the pricing policies of third parties, nor do we threaten third parties with exclusion from future tenders.
Question
I am attending an industry meeting and sitting next to a competitor who is discussing his organisation’s pricing strategy. I am not discussing any information about Implenia, so is this OK?
Answer
No. Discussing any competition-related information about any organisation is problematic and requires you to withdraw from the conversation and report the incident to Compliance immediately.
3. Our commitment to the environment
Thinking about tomorrow today
How can we act sustainably?
We pursue sustainable approaches, including making workplace decisions that minimise negative impacts on the climate and the environment, and advocating for future-proof building standards. We take sustainability and environmental considerations into account throughout the entire value chain when making purchases (e.g. closing material cycles and using recycled or recyclable products, or products made from renewable raw materials), and we rectify any obvious errors that could lead to pollution or non-compliance with environmental legislation. We support innovation and invest in sustainable new products and solutions. We never simply accept unsustainable practices; instead, we take action to tackle and resolve them.
WE DO
- We are all role models! We act sustainably in all decisions we make at work.
- We are aware of our sustainability goals and work towards achieving them; we comply with all applicable environmental laws, regulations, standards and sustainability targets, whilst implementing an effective system to identify and eliminate environmental threats.
- We immediately report environmental incidents to the relevant supervisor and the Sustainability/Safety specialist, who must then draw up a report in accordance with our Incident Management Directive.
- We use equipment and machinery efficiently and switch them off when not in use.
- We take measures to prevent pollution and to reduce our carbon dioxide emissions and our consumption of energy and resources.
WE DON’T
- We do not generate avoidable waste. We recycle unavoidable waste wherever possible and dispose of the rest properly.
- We do not ignore environmental impacts; instead, we seek to address and minimise their causes.
- We do not accept behaviour that could lead to pollution or non-compliance with environmental legislation.
- We do not shy away from the potentially higher investment costs of a new product or solution. Instead, we think in terms of life cycles and consider whether the life-cycle savings might outweigh the additional investment costs.
4. Our Assets, Knowledge and Resources
SHH!
How can we keep secret things secret?
We keep confidential information belonging to Implenia, our customers and our suppliers confidential, and we never make use of inside information. We do not disclose confidential information to third parties, including our family and friends, except where a non-disclosure agreement is in place and the Legal & Compliance Department has approved the disclosure. We neither use nor share information that may affect the market price of Implenia shares or the securities of any other company, nor do we use or share inside information for the purpose of trading in any securities.
WE DO
- We protect our confidential information and trade secrets from unauthorised disclosure and misuse, even after we leave Implenia.
- We remain aware of where we are, who is around us and what they might see or overhear.
- We use social media responsibly and follow our Social Media Usage Policy.
WE DON’T
- We do not speak on behalf of Implenia to the media or any third party, and we contact the Marketing/Communications department if we receive a request from a journalist.
- We do not disclose confidential information to other members of our organisation who are not authorised to receive it.
Question
My cousin works for an organisation that Implenia is going to acquire. I assume she is also aware of the acquisition, even though the information is confidential and has not yet been made public, so is it OK to talk to her about it?
Answer
No. We keep confidential, non-public information secret from everyone, even those closest to us.
Careful use of company property
How do we use and protect our resources, data and assets?
We are committed to protecting Implenia’s resources and assets from damage, misuse, waste, improper disposal or theft, and we use company resources only for their intended purposes. We are all responsible for ensuring that company data is maintained in a timely, accurate and complete manner, which means we must ensure that it is never lost, damaged, falsified or misused. All company resources and assets, such as physical assets, documents, knowledge and intellectual property, belong to Implenia. If we need to dispose of our resources or assets, we must do so in accordance with our Internal Rules and only if we are authorised to do so.
WE DO
- We always use assets in accordance with our IT Acceptable Use Policy.
- We respect and protect our intellectual property and that of third parties in accordance with the terms of all applicable contracts, and never use software that has been illegally copied or purchased.
- We maintain timely, accurate and complete records of our data, information and documents that we have created or for which we are responsible (such as annual reports, project or tender documents, expense claims or emails).
- We keep all business records and data secure, follow all of Implenia’s data security procedures and comply with any records management and document retention procedures.
- We always consult our Table of Responsibilities and Rules and Regulations on Signing Authority and comply with them before signing contracts, checking invoices, etc.
WE DON’T
- We do not use our computer systems, company email accounts or the internet inappropriately, and we only grant access to IT tools when they are necessary for carrying out work tasks.
- We do not share our login details (i.e. username, password) with colleagues or any third parties.
- We do not lend, transfer, sell or donate company assets to third parties without proper authorisation.
- We do not use systems (including company emails) in an abusive, disruptive or otherwise harmful manner. This includes creating, displaying, saving or sending pornographic images or racist or discriminatory content.
5. Our Working Environment
All equally different
How do we treat one another?
We maintain a safe, equitable, inclusive and diverse workplace where everyone can feel at ease and is treated politely and respectfully, and where differences are welcomed and harnessed to achieve better business results. We should avoid statements or actions that offend or hurt others, including any unpleasant or derogatory remarks or actions based on ethnic origin, skin colour, nationality, race, political and religious views, beliefs, gender, gender identity, sexual orientation, age, culture, disability, illness or family circumstances, as well as membership or non-membership of a trade union and trade union activity. We do not tolerate discrimination or harassment in the workplace. This applies in particular to sexual harassment, which includes verbal comments, gestures, remarks or touching of a sexual nature. We do not turn a blind eye; we take action.
WE DO
- We speak up and report harassing or discriminatory behaviour to our line manager, HR or Compliance.
- We are all role models, and we treat others with tact, courtesy, respect and fairness
- We adhere to fundamental labour and human rights as set out in international conventions, programmes and standards, such as the United Nations Universal Declaration of Human Rights. In particular, we ensure fair wages and freedom of association, and we do not tolerate child labour or forced labour.
WE DON’T
- We do not engage in harassing behaviour, including verbal, non-verbal and written slights, humiliation, insults or threats, nor do we take part in any form of social exclusion, ostracism or deliberate and persistent persecution of a person.
Safety first
How do we stay healthy and safe?
We care about and take responsibility for our own health and safety and that of others. We seek to eliminate hazards and reduce risks in order to prevent illness and injury. We have a systematic approach to identifying hazards and managing risks appropriately within each unit, project and joint venture.
WE DO
- We identify health and safety risks and eliminate or minimise them before we start work.
- We promote a health and safety culture by consistently acting in a responsible and exemplary manner.
- We report to our line manager or health and safety representative if health or safety at work is compromised in any way, including all incidents, even near-misses.
- We follow our safety rules, and we say “stop” in unsafe or non-compliant situations.
WE DON’T
- We do not work whilst under the influence of alcohol or other substances, and we do not organise any events on our premises where alcohol will be consumed after work without prior proper approval.
Question
I am working with equipment that has a faulty safety mechanism. Replacing or repairing the equipment will cause our team to fall behind schedule on the project. Should I continue to use the equipment?
Answer
No. We do not compromise on safety. Whilst we pride ourselves on delivering on time, safety always comes first, and the equipment must be repaired or replaced before you continue to use it.
Privacy
How do we respect each other’s privacy?
We keep personal information confidential and comply with applicable laws and our privacy principles. We securely collect, store, host, process, transmit and use personal data; we ensure that we collect and use data only where we have a legal basis to do so, where it is necessary and where it is for a specific business purpose; and we provide it only to authorised persons. We do not share personal data outside our organisation unless required by law, when using a third party to collect data, or when we have obtained consent to do so from the individual concerned. When using third parties to collect, host, use or process personal data in any other way, we ensure that they process personal data only in accordance with our authorised practices, including by signing a data processing/sharing agreement and complying with our privacy principles.
WE DO
- We respect our colleagues’ right to privacy.
- We comply with the data protection principles set out in our Global Data Protection Directive.
WE DON’T
- We do not collect “sensitive” personal information (particularly biometric data, such as facial or vein scans, or information relating to health status, ethnic origin, sexual orientation, political views or religion) without consulting our Data Protection Team for guidance.
- We do not grant access to personal data to any unauthorised persons within our organisation. Such data is shared strictly on a ‘need-to-know’ basis.
6. Using our code
We stand up for what is right
Speak up! Ask questions!
Only with our collective support can we foster a successful compliance culture that enables our business to thrive.
Where can I make a report?
You can use our Speak Up Line to report your concerns about compliance or a possible breach.
Who can submit a report or ask a question?
Implenia promotes a culture that encourages everyone to speak out freely. Anyone, whether an employee or not, can report a potential case of misconduct in good faith. Such a report can also be made anonymously.
What happens when a potential case of misconduct is reported to Compliance?
Any suspected breaches of this Code, other internal rules or applicable laws will be thoroughly investigated by the Compliance department. In the event of confirmed misconduct, the relevant decision-making body may impose sanctions.
What happens to the whistleblower?
Implenia does not tolerate retaliation against those who make reports in good faith based on credible concerns. Anyone who is aware of – or suspects – a breach of our Code, Internal Rules or laws should feel safe to report it.
7. Downloads
Download PDF documents here
