Code
of Ethics
K L I M A - T H E R M G R O U P
Dear Customers,
Business Partners
and Employees,
The KLIMA-THERM Group bases its operations on responsibility, integ-
rity, professionalism, and mutual respect. We believe that sustainable
growth is possible only when we pursue our business objectives in a
lawful and transparent manner, taking into account the impact of our
decisions on people, the environment, and the business community.
This Code sets out common standards of conduct and helps us make
sound decisions in our daily work. Each of us is responsible for complying
with it - regardless of the nature of our relationship with KLIMA-THERM
Group companies, our position, workplace, or scope of responsibilities.
The Management Board of the KLIMA-THERM Group
Table of Contents
01
Purpose, scope, and application of the Code
02
Our mission, values, and responsibility
03
Compliance with the law and responsible
business practice
04
Respect for human rights
05
Work environment, equal treatment,
and organizational culture
06
Relationships with customers, partners, and suppliers
07
Fair competition and antitrust law
08
Anti-corruption and conflicts of interest
09
Financial integrity and protection of the Group’s assets
10
Information, data, cybersecurity,
and responsible technologies
11
Environmental responsibility and ESG
12
Community engagement and community relations
13
Reporting concerns and whistleblower protection
14
Management responsibility
implementation, and consequences
15
Final provisions and contact information
04
06
10
12
16
18
20
22
26
28
30
32
34
36
38
Purpose, scope
and application
of the Code
01
The Code of Ethics is a practical standard
for making responsible decisions.
This Code of Ethics of the KLIMA-THERM Group (the ‘Code’) sets out
the shared values and standards of conduct applicable across all com-
panies within the KLIMA-THERM Group (the ‘Group’). It supplements,
but does not replace, applicable laws, contracts, internal policies, pro-
cedures, and regulations.
The Code applies to members of the governing bodies of Group com-
panies, management, employment – and persons of position or form of
employmen – nd persons acting on behalf of or for the benefit of the
Group, including contractors, consultants, interns, and apprentices. We
expect our business partners, suppliers, and subcontractors to adhere
to equivalent standards in their cooperation with the KLIMA-THERM
Group.
•
We comply with the laws in effect in every country where
we operate.
•
If statutory provisions establish a stricter standard than the Code,
we apply the statutory provisions. If the Code provides for
a higher standard, we apply it to the extent permitted by law.
•
No sales, financial, or operational goal, nor any deadline, justifies
a violation of the law, safety, or ethical principles.
•
Everyone is required to familiarize themselves with the Code,
apply it in their work, and respond to potential violations.
If you are unsure, stop what you are doing and consult your supervi-
sor, the HR department, the appropriate legal department, or use the
available reporting channels. Asking a question or raising a concern in
good faith is expected behavior, not a sign of disloyalty.
Our mission,
values and
responsibility
02
WE CARE ABOUT AIR
We care about air quality, human comfort,
and a responsible business environment.
The slogan “We care about Air” captures the essence of our busi-
ness: we develop technologies and provide heating, ventilation
and air conditioning (HVAC) solutions that improve air quality and en-
hance comfort in both home and work environments. The way we
achieve our business results is just as important as the results them-
selves.
The Values That Guide Our Decisions
•
Responsibility – We consider the impact of our actions on our cus-
tomers, employees, partners, the environment, and society.
•
Integrity – We tell the truth, honor our commitments, and do not
withhold information that is essential for making the right decision.
•
Respetct – We protect the dignity, safety, and rights of every
person.
•
Partnership – We build relationships based on dialogue, integrity,
and mutual trust.
•
Professionalism – We operate competently, diligently, and to the
best of our knowledge.
•
Growth and Innovation – We continuously improve our solutions
while maintaining our commitment to safety, data protection, and
social impact.
•
Environmental Stewardship – We minimize the negative impact
of our operations and support the transition to a low-carbon and
circular economy.
Ethical Decision – Making Test
– Before You Act
If the situation you're facing isn't clear-cut, pause and
answer the questions below. Even one answer that
raises doubts is a sign that you should seek advice
before taking action.
1. Is this action in compliance with the law, the Code,
and internal policies?
2. Is it fair, safe, and in line with our values?
3. Can I clearly explain the purpose and method of
this action?
4. Would I be comfortable if this decision were made
public or reviewed by an independent person?
5. Could this action harm people, the environment,
the KLIMA-THERM Group, or its stakeholders?
If in doubt: do not act on your own – peak with your
supervisor, a representative from HR, IT & Administra-
tion, the Legal Department, the Data Protection Offi-
cer, or use the reporting channels listed in Chapter 13.
10
03
Compliance with the
law and responsible
business practice
11
We operate legally, transparently,
and with due diligence.
All individuals carrying out professional responsibilities, performing
assigned duties, or acting on behalf of companies operating within the
KLIMA-THERM Group are expected to comply with the laws, internal
policies and procedures and standards applicable to their areas of re-
sponsibility. The organization supports this commitment by providing
access to relevant information, training, and professional guidance.
•
We do not involve the Group or its resources in any
illegal activities intended to circumvent the law or conceal the true
nature of a transaction.
•
We comply with requirements regarding economic sanctions, em-
bargoes, trade controls, anti-money laundering and counter-ter-
rorist financing – to the extent that they apply to our operations.
•
We cooperate fully with competent authorities, auditors, and
inspectors, without hindering access to accurate and complete
information.
•
We do not destroy, conceal, or alter documents that may be rele-
vant to audits, investigations, or record-retention requirements.
Any questions regarding laws or procedures should be addressed be-
fore entering into a contract, making a payment, sharing data, beginning
a business relationship with a new entity, or entering a new market.
12
Respect for
human rights
04
13
We respect human dignity and human
rights in the workplace, in our business
relationships, and throughout the entire
value chain.
The KLIMA-THERM Group is committed to respecting internationally
recognized human rights, in particular those set out in the Internation-
al Bill of Human Rights and the fundamental principles and rights at
work recognized by the International Labour Organization (ILO). We are
guided by the UN Guiding Principles on Business and Human Rights
and the OECD Guidelines for Multinational Enterprises on Responsible
Business Conduct. In every country, we comply with applicable laws,
and in the event of discrepancies, we strive – within the limits of the
law – o apply the standard that ensures a higher level of human rights
protection.
We respect the dignity of every person, regardless of origin, skin color,
gender, age, nationality, language, religion, worldview, beliefs, disabili-
ty, health status, sexual orientation, identity, family status, union mem-
bership, employment status, or other characteristics protected by law.
We do not tolerate human rights violations in our own operations or in
our relationships with customers, partners, suppliers, subcontractors,
and local communities.
The principles of the Code apply to members of governing bodies,
management, employees, and other persons acting on behalf of or for
the Group. We expect our partners, suppliers, and subcontractors to
adhere to equivalent standards. We take these expectations into ac-
count – in proportion to the level of risk – in our selection processes,
contracts, performance evaluations, and corrective actions.
14
In particular, we are committed to:
•
combating discrimination, workplace bullying, psychological and physical abuse,
harassment, sexual harassment, intimidation, retaliation, and unequal treatment;
•
ensuring safe, healthy, hygienic, and dignified working conditions,
as well as compliance with policies and procedures regarding wages, working
hours, rest periods, and the protection of health and life;
•
promoting equal opportunities in recruitment, hiring, compensation, professional
development, and promotion based on transparent criteria related to competen-
cies, responsibilities, and job performance;
•
respecting for the right to privacy, freedom of expression, freedom of association,
and collective bargainin – in accordance with the law and with respect for the
rights of others, confidentiality, and professional obligations;
•
combating forced labor, human trafficking, child labor, modern slavery, and all
forms of exploitation;
•
identifying, assessing, preventing and mitigating – n a manner commensurate with
the nature and scale of the riks – the potential adverse human rights impacts of
our operations, products, services, and business relationships on people, with par-
ticular attention to individuals and groups that are more vulnerable to harm;
•
taking or supporting remedial actions if the Group has caused or contributed to a
negative impact on human rights, incorporating our leverage with Partners if the
risk or violation is directly linked to our operations, products or services through a
business relationship;
•
taking human rights criteria into account when selecting and evaluating Partners,
Suppliers, and Subcontractors, and expecting them to effectively prevent and
respond to violations and implement agreed-upon remedial actions.
Every Employee and Associate is required to report any observed or suspected hu-
man rights violations. Reports may be submitted to a supervisor, the HR department,
or through the channels described in Chapter 13. Individuals who report in good faith
are protected from retaliation.
15
16
Work environment,
equal treatment,
and organizational
culture
05
17
We create a safe environment based on
respect, dialogue, and responsibility.
The commitment, competence, and well-being of our employees are
the foundation of the KLIMA-THERM Group’s success. We want every
employee to be able to do their job without fear of humiliation, vio-
lence, retaliation, or exclusion.
•
We communicate in a professional and respectful manner, even
when there are differences of opinion or time pressure.
•
We do not tolerate behavior that is offensive, aggressive,
sexualized, retaliatory, or that violates personal boundaries.
•
We make employment decisions based on competence,
performance, potential, and legitimate organizational needs.
•
We prioritize occupational safety and health, ergonomics,
preventive measures, and the reporting of hazards and near-miss
incidents.
•
We support professional development through training, feedback,
knowledge sharing, and access to development opportunities in
line with the organization's needs.
•
We respect privacy and the right to a private life. However, we
expect that public statements and activity on social media will not
unjustifiably harm the reputation of the KLIMA-THERM Group as
an organization or of individual companies as employers, disclose
confidential information, or infringe on the rights of others.
Management has a particular responsibility to prevent conduct
that violates human dignity, respond promptly to concerns, and
create an environment in which issues can be raised openly.
18
Relationships with
customers, partners,
and suppliers
06
19
We build trust through quality, reliable
information, and honest commitments.
We treat our customers and partners with professionalism and re-
spect. We offer solutions that meet their actual needs, provide infor-
mation in a comprehensive and understandable manner,and we do not
take unfair advantage of information asymmetries.
•
We ensure the quality, safety, and compliance of our products
and services, and we report and resolve any identified risks or
nonconformities without undue delay.
•
Sales and marketing materials must be truthful, verifiable, and free
of misleading claims, including environmental claims.
•
We present the terms and conditions of our offers, contracts,
warranties, service, and billing in a clear and transparent manner,
without any hidden obligations or undue pressure.
•
We protect the confidential information, personal data, and intel-
lectual property of our customers and Partners with at least the
same level of care as we do for the KLIMA-THERM Group’s own
assets.
•
We select suppliers and subcontractors based on objective crite-
ria such as quality, safety, commercial terms, competence, legal
compliance, environmental impact, and ethical standards.
We do not take any actions that might appear to improve short-term
results at the expense of safety, quality, the customer’s interests, or
the Group’s reputation.
20
Fair competition
and antitrust law
07