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    CODE OF CONDUCT

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    This Code of Conduct applies to the TOPMOTIVE Group, including DVSE GmbH and all subsidiaries and affiliated companies.

    A current overview of the TOPMOTIVE Group is available at the following URL: https://topmotive.eu/unternehmen/.

    The list is updated regularly and forms the basis for the validity of this Code of Conduct. These companies will be referred to below as ‘TOPMOTIVE’. Responsibility for the content of this Code of Conduct lies with the management of TOPMOTIVE.

    Preamble

    As a family-owned company since 1994, we at TOPMOTIVE are not only the technology leader in the independent automotive aftermarket, but also a group of companies with clear values that actively assumes social responsibility.

    This Code of Conduct sets out the basic principles and rules of behavior for all employees, managers, management and external business partners of the TOPMOTIVE Group. It serves as a guideline for ethical and legally compliant behavior and underlines our commitment to integrity, fairness and sustainability.

    All persons acting on behalf of TOPMOTIVE are obliged to comply with this Code of Conduct.

    1. Integrity And Fairness in Business Dealings:

    We act with integrity, fairness and transparency at all times.

    •  All business decisions must be based on objective criteria and must not be influenced by personal interests.
    •  Discrimination, harassment of any kind or unfair treatment have no place in our company.
    • All persons affected by this Code of Conduct are fully committed to respectful and appreciative cooperation – regardless of origin, nationality, ethnicity, gender, sexual identity, religion or ideology, age, physical or mental ability or social status.
    2. Prohibition of Corruption and Bribery:

    We do not tolerate any form of corruption, bribery or undue influence.

    •  It is strictly forbidden to offer, promise, grant, demand or accept direct or indirect bribes, kickbacks or improper advantages – regardless of whether these are business contacts, customers or public bodies.
    • This applies both to representatives of the private sector and to public officials.
    3. Gifts, invitations and other benefits:
    • Gifts, invitations or other benefits may only be offered or accepted if they
    • are socially customary,
    • are of low value and
    • are not likely to influence business decisions or create an appearance of impropriety.
    • Special care must be taken when dealing with public officials: Stricter legal requirements often apply here. Before granting or accepting any benefits in such cases, they must be reviewed or approved by the management.
    4. Commissions, brokerage and consultancy fees:
    • Commissions and comparable remuneration may only be paid on the basis of written contracts and for verifiable services actually rendered.
    • Payments to intermediaries, agents or consultants that serve solely to circumvent legal requirements or ethical standards are not permitted.
    5. Dealing with Conflicts of Interest:

    All employees are obliged to disclose potential or actual conflicts of interest.

    • Private interests must not influence business decisions.
    • Secondary employment or shareholdings in competitors or business partners must be reported to the management if a conflict of interest could arise as a result.
    6. Compliance with Laws and Internal Regulations:

    We are committed to complying with all applicable legal provisions, industry-specific requirements and internal guidelines at all times.

    • New or supplementary internal guidelines that are issued in the future are a binding part of this Code.
    7. Responsibility for the Company's Reputation:

    Everyone is jointly responsible for maintaining and strengthening the trust of customers, partners and the public in TOPMOTIVE.

    • Behavior that damages the integrity, credibility or reputation of TOPMOTIVE must be refrained from. This applies both in a professional environment and in a private context. Even outside working hours, employees should be aware that their own actions can have an impact on TOPMOTIVE – especially their behavior and appearance in digital spaces such as social media.
    8. Information And Reports:

    Violations of this Code or applicable law should be reported to the management or one of the reporting centers named below.

    Which reporting channels can be used?

    • E-mail: compliance@topmotive.eu
    • Phone: +49 4532 9740 – 444
    • Anonymous: Bargteheide site: Compliance mailbox
    • Via mail to: (located on the 2nd floor)
      DVSE GmbH
      c/o Compliance mailbox
      Lise-Meitner-Str. 4, 22941 Bargteheide

     

    TOPMOTIVE ensures that whistleblowers do not suffer any disadvantages as a result of reporting in good faith in accordance with the principles and regulations of the Whistleblower Protection Act of 31 May 2023.

    9. Final provisions:

    This Code of Conduct is binding for everyone acting on behalf of TOPMOTIVE. It applies in addition to all existing and future internal guidelines and is reviewed annually.

    As of December 2024

    Code of Conduct Report Form

    Your Report will be submitted anonymously. If you would like to receive feedback, please include your contact details. Our team will respond within one week.