Introduction
Our standards of conduct – things to know
Step 1: LEGAL compliance
o Compliance with applicable law
o Commitment to free and fair competition
o Occupational safety and health; environmental protection
Page 3
Control is good – TRUST is better
o Gifts and perquisites
o Confidential information and data protection
o Company property
FAIRNESS in freight
o Dealing fairly with each other
FCS pledges
o Loyalty toward the company’s interests
Good things come in threes! F C S !!!
o Quality
Introduction
An American writer once said, “In business, honesty is a sure sign of insanity.”
This view was acceptable in our world as well for a long time. What is considered honest and permissible in dealings with business partners and what isn’t? The lines are often blurred, and there are cultural differences as well.
Small tokens of one’s appreciation, deliberate influence, accepting gifts with clear aims – we are all faced with temptation. But how do we handle it? When does a favor or small token of appreciation cross the line into exerting an influence? There are no clear rules here, no stoplight that changes from green to red, but there are some principles we can turn to for guidance in dealing with enticements of all kinds.
These guidelines are intended to provide specific guidance for your actions, describing how we uphold our basic values of honesty, integrity, trustworthiness, responsibility, loyalty, transparency, and fairness. These are the values we embrace in our work, and they allow us to operate successfully on the market in the long term and sustainably. Please take the time to consider our values and don’t hesitate to reach out if you have any questions. The contact persons mentioned below will be happy to help you.
After all, honesty is always the best policy, as the saying goes.
Our standards of conduct – things to know
Why do we need standards of conduct?
As the largest airline-independent cargo handling company at Frankfurt Airport, we – FCS Frankfurt Cargo Services GmbH (FCS) – aim to live up to our responsibility from an ethical, social, and economic standpoint as well as toward the environment. That’s why we apply the very highest standards when it comes to our basic values of honesty, integrity, trustworthiness, responsibility, loyalty, transparency, and fairness.
These standards of conduct serve to show what kind of conduct all employees are expected to display toward the company, their work colleagues, and third parties. It’s about how we do business – everywhere, all the time.
By abiding by these standards in everything we do, we can all do our part to ensure that we work for a company we can all be proud of.
Do I have to observe these standards?
These standards of conduct are in keeping with our pledge to conduct ourselves in a legally compliant and ethical manner. This means we always offer our services in a fair, honest, and legally permissible way. When you work for FCS, you undertake the same obligation. Every employee, at every level of the management, is obligated to comply with these principles of conduct.
Please familiarize yourself with the guidelines below and the rules that apply to your work and be sure to observe them at all times. Failing to observe these standards will place you, your colleagues, and your company, FCS, at risk.
Be sure to abide by these principles at all times – no ifs, ands, or buts. Ignorance is no excuse.
In real life, of course, there is no way to prevent every single violation. That’s why we expect all of our employees to report any sign of violations of applicable laws and our guidelines or standards of conduct. No employee who reports a possible violation of the standards of conduct in good faith and based on concrete facts will suffer any adverse consequences as a result. We pledge to treat all reports received by our compliance and values management officers as absolutely confidential.
Does this include all rules that apply to me?
These standards of conduct are not intended to reflect all legal provisions and internal guidelines that might possibly apply to you in detail. They are not intended to predict everything or set out corrective or punitive actions to apply in all situations.
In many cases, common sense and individual responsibility are enough to get through a normal working day in compliance with these principles.
Where do I turn if I have questions, need concrete support, or want to report a violation?
If you have any questions about the law or your conduct in your day-to-day work, need concrete support, or want to report a violation of the standards of conduct, your direct supervisor is generally your first and best point of contact.
You can ask questions whenever you have any doubt about whether you are conducting yourself in keeping with these guidelines. A good rule of thumb here is to ask before you act, and to keep asking until you have a final answer. Seeking advice or expressing concerns in good faith is always in accordance with these principles of conduct and is always correct.
In situations of conflict involving your specific workplace, you can contact not only your manager, but also the designated persons of trust. Our persons of trust are obligated to maintain secrecy (including toward the executive management and/or Executive Board of Fraport AG) and cannot be released from this obligation except by the person who makes the report him- or herself.
• Person of trust at FCS Frankfurt Cargo Services GmbH
Mr. Gordan Bartol
Phone: 069-690 78218
Mobile: 0173-6998928
e-mail: This email address is being protected from spambots. You need JavaScript enabled to view it.
• Person of trust at Fraport AG
Mr. Frank Cornelius
Phone: 069-69714853
Mobile: 0172-6630638
e-mail: This email address is being protected from spambots. You need JavaScript enabled to view it.
If you suspect that a serious crime has been committed, you can also contact the Fraport Group’s external ombudsperson, Annette Parsch, Attorney at Law. Ms. Parsch’s main task is to accept confidential reports of company-related crimes and impermissible business practices, along with violations of rules that may harm the company.
• Attorney at law, ombudsperson
Ms. Annette Parsch
Specialized Attorney for Criminal Law
Q 2, 5, 68161 Mannheim
Phone: 0800 1230125
e-mail: This email address is being protected from spambots. You need JavaScript enabled to view it.
For further information, please visit www.ombudsfrau-parsch.de.
If you have a concern that you would not like to discuss personally with someone or would like to raise anonymously, you can use the electronic whistleblower system. This is a certified reporting system where reports can be made in your own name or with absolute anonymity if you wish. The system is available to all employees, suppliers, and business partners as an Internet-based electronic whistleblower system anywhere, anytime, 24 hours a day.
To reach the system, go to
• www.fcs.wfs.aero under“Company” → “Compliance & data protection”
• www.fraport.de under “Our Group” →“Goals and Values” →“Compliance”
Step 1: LEGAL compliance!
Compliance with applicable law
We view compliance with all national and international laws and regulations that apply to our actions as a company as a matter of course. We handle our processes and business transparently and cleanly and do not accept any conduct that casts doubt on or jeopardizes our integrity.
To that end, we comply with the provisions and regulations that apply to us strictly and without exception.
Commitment to free and fair competition
Our business policies call for engaging in and promoting fair competition. Even as we compete rigorously with other market participants, our actions are always fair and legally compliant. We reject all forms of business conduct aimed at obtaining a financial advantage in a manner that is unfair in terms of the law of competition.
Occupational safety and health; environmental protection
The safety and health of our employees comes first! With that in mind, we are ever-vigilant about safety in the workplace and take precautions to prevent recognizable risks.
Still, workplace safety can only be ensured if each and every one of us observes the applicable legal and airport-specific safety standards at all times. Compliance with all of the relevant safety rules is a basic prerequisite for responsible dealings with each other.
We also strive to minimize the adverse impact of our business activities on the environment. This goal requires support from everyone who works for FCS.
Through our conduct, all of us can make a big contribution to protecting the environment by being responsible and conservative in our use of resources, especially office supplies and packaging materials, protecting natural resources, and being sure to dispose of waste properly and with minimum environmental impact.
Control is good – TRUST is better!
Gifts and perquisites
Our business policies call for doing business fairly and honestly. Starting from this principle, we do not grant or accept gifts, perquisites, invitations, or other benefits in exchange for our services.
The only exceptions are gifts that are in keeping with customary practices and are not given in exchange for preferential treatment.
The following principles offer guidance for proper handling of gifts and perquisites:
You can accept:
• Token gifts with minor or symbolic value that are appropriate to the business relationship.
• Invitations to business meals within a scope and amount appropriate to the occasion (the maximum for tax purposes, currently 35 euros*, is a good benchmark here).
• Invitations to product and/or information events outside the airport, provided that the travel expenses are fully assumed by FCS within the scope of a business travel request.
The following must not be accepted under any circumstances:
• Money or benefits with monetary value (e.g., cash, transfers or loans of any kind, unusual compensation or compensation out of proportion to the service for private side activities, gift certificates, flight tickets, invitations to vacation trips, provision of objects for use free of charge or at a reduced rate, etc.).
• Material assets and other assets, where these exceed the maximum for tax purposes* (e.g., spirits, clothing, jewelry, event tickets, gift certificates or vouchers).
• Gifts, perquisites, and other services that are illegal or do or may violate applicable law.
• Gifts and perquisites that are part of an unofficial agreement and involve a commensurate obligation in return.
*German Income Tax Act (EStG), Sec. 5, first sentence, No. 1
Accepting any services or benefits that do not already fall within one of these categories may he permissible or impermissible. In case of doubt, you should always consult your direct supervisor.
Exceptions and deviations from these rules require documentation and the approval of the relevant supervisor at all levels.
Confidential information and data protection
We observe our employees’ rights and those of third parties with regard to personal data and take appropriate precautions to ensure that personal data are collected, processed, and used in strict compliance with the applicable provisions in all cases. All of us are only permitted to use knowledge of confidential internal projects or processes for business-related purposes. Professional, confidential information must not be shared with third parties orally, in writing, or electronically.
As a matter of course, we handle confidential information received from our customers or business partners with the same level of responsibility.
Our executives and administrative employees receive regular training on this.
In case of doubt, please feel free to contact the data protection officer of FCS Frankfurt Cargo Services.
Florian Kaiser LL.M., Tel. +49 (0)69 27 13 57-0, This email address is being protected from spambots. You need JavaScript enabled to view it..
Company property
Each and every one of us is obligated to treat company property responsibly, properly, and with care.
As a basic principle, company property must be used for work-related purposes only. Equipment and objects belonging to the company or our customers must not be used for personal purposes or taken off the premises without express approval from the executive management.
FAIRNESS in freight!
Dealing fairly with each other
Cultural diversity is one of the things that set our company apart. FCS is obligated to refrain from disadvantaging, harassing, and discriminating against employees in any form, and the same obligation applies to employees themselves. Collegial interpersonal behavior forms the basis for a positive, balanced working climate and is a key prerequisite for achieving our goals as a company.
Each and every one of us is obligated to contribute to a positive working climate and respect the individuality of all our colleagues and external parties alike. We expect everyone to treat their colleagues and customers respectfully, objectively, and fairly.
FCS pledges
Loyalty toward the company’s interests
We want a company we can all be proud of. Our actions as a group are characterized by loyalty and objectivity, and we avoid conflicts of interest.
A conflict is present in any case where a person’s own interests compromise their ability to act or make decisions in the company’s interest. Conflicts of interest can arise in a variety of different circumstances. All of us are required to avoid situations that lead or could lead to a conflict between our personal interests and the interests of the company.
• In the case of contract awarding and procurement procedures, employees involved must disclose if members of their family or friends have substantial financial stakes or interests in suppliers. Possible conflicts of interest must be reported in writing to the employee’s supervisor without delay.
• Acquiring or holding any major stake in a company that competes with FCS or any of its affiliates is prohibited for the duration of the employee’s employment unless FCS has consented in advance. Acquiring or holding any major stake in a company that maintains business relations on a non-trivial scale – directly or indirectly – with FCS or any FCS affiliate requires written notification, including information on the nature and scope of the stake in question.
• Any side employment or similar activity must be reported in writing to the HR department of FCS in good time before it starts. This also applies to holding any public honorary position.
Good things come in threes: F C S
Quality
We perform high-quality services geared toward our customers’ needs. Maintaining this high quality is crucial to our continued success.
Flexible, customer-oriented process design, an extensive range of services, and first-class service is what our customers expect from us, and it is what sets us apart from other cargo handling companies. To meet these expectations while also accommodating every single customer request as best we can, each and every one of us must uphold the company’s internal quality standards as well as the safety regulations imposed by government agencies and the airport-specific safety requirements.
The good reputation FCS enjoys due to its innovative logistics concepts and high service quality is in our hands, each and every day.