Code of Conduct

We want to do what is right – our Whistleblowing Service

We strive to maintain transparency as well as high business ethics. Our whistleblowing service provides an opportunity to communicate on suspected wrongdoings affecting people, our organisation, society or the environment. The whistleblowing service makes wrongdoings less likely to occur in the first place and shows our commitment to operate in a fair way. You do not need proof of your suspicions, but all messages must be made in good faith.

You can raise your concern anonymously by using our Reporting channel, managed by a third-party.

Reporting channel, allowing anonymous messaging and dialogue: https://report.whistleb.com/en/eos

The whistleblowing service is provided by an external partner WhistleB, Whistleblowing Centre, to ensure anonymity. The communication channel is encrypted and password-protected.

All messages will be processed in confidence.

1. INTRODUCTION

  • All EOS Group Companies (“EOS”, “we” or “us ”) are committed to contributing to good and healthy living, providing sustainable experiences and enjoyment, minimizing their carbon footprint and creating a safe and warm community to their key stakeholders.

  • This Supplier Code of Conduct (the “Code ”) contains uniform binding key requirements for any individual or legal entity which provides us with any goods or services or with whom we cooperate in any way or form (collectively the Partner(s)’s)”). We at EOS are committed to this document in full and expect the same from our Partners.

  • By accepting this Code, the Partner agrees to comply with the terms of this Code in respect of its business transactions with us and in its dealings with its own employees, suppliers, business partners and other stakeholders.

  • The Partner agrees to ensure that its own suppliers, service providers and business partners comply with the obligations set out in this Code in respect of any deliveries to EOS.

  • All questions and notification related to this Code can be directed to the Partner’s respective contact person at EOS or Purchasing Director Frank Bildat. If the document is signed on its own, the signed version can be delivered to einkauf@eos-sauna.de.

 

2. LEGAL AND REGULATORY COMPLIANCE

  • Together with this Code, the Partner shall comply with all mandatory laws and regulations, authority orders and decisions as well as any other relevant statutory standards (the “ Rules ”) applicable to its operations.

  • As we have Partners in many different parts of the world, it is the Partner’s sole responsibility to familiarize and monitor local Rules and modify its policies and actions accordingly.

  • The Code does not substitute or override mandatory laws and regulations. If the requirements of this Code contradict any applicable mandatory laws and regulations, the Partner shall follow the laws and regulations, but aim to adhere to the spirit of this Code. However, the requirements in this Code may go beyond applicable Rules, in which case this Code prevails.

  • Without limiting the generality of the foregoing, the Partner agrees as follows:

    • Condemning all corruption. We expect our Partners to condemn all bribery and corruption. Partners are required to uphold standards or procedures to make sure that no one acting on their behalf offers bribes or other improper payments to obtain new clients or to retain existing clients or to secure any other unjustified advantages. The Partner is not allowed to provide our employees with any gifts or hospitality above customary standards which might influence, or might appear to influence, our decisions related to the Partner. Providing a gift of cash is never acceptable.

    • Fair competition. We expect our Partners to comply with all applicable antitrust and competition Rules, which includes not discussing prices, market sharing, bid rigging or similar activities with its competitors.

    • Avoidance of conflicts of interests. The Partner agrees to steer clear from any situations where a conflict of interest between the Partner and EOS exists or might exists. This includes interactions with our employees that could lead to a conflict of interest with that employee’s duty to act in our best interests. The Partner must also reveal any potential or existing conflict of interest situation in relation to EOS.

    • Anti-money laundering, privacy and trade sanctions. The Partner shall comply with all applicable Rules related to anti money laundering, to privacy and data protection as well as adhere to all applicable economic and trade sanctions.

    • Intellectual property rights and confidentiality. The Partner shall make sure that it does not infringe EOS’ or any third party’s intellectual property rights during its operations. The Partner is not allowed to use EOS’ name, logo or trademark or publicize our business relationship in any way without our written approval. The Partner also agrees to keep all material it receives from EOS before, during or after the business relationship confidential, unless otherwise agreed between us and the Partner in writing.

 

3. HUMAN AND LABOR RIGHTS

  • We respect all internationally recognized human rights and expect our Partners to do the same.
  • Without limiting the generality of the foregoing, the Partner agrees as follows:
    • i. adhere to all mandatory employment Rules, regarding for example minimum wage, working conditions and working hours;
    • ii. make sure that all employees are made aware of the exact terms of their employment before the start of their employment relationship;
    • iii. not employ any workers younger than 15 or the local minimum working age;
    • iv. not tolerate any direct, indirect, physical, psychological or verbal harassment of employees;
    • v. respect employees’ right to organize collectively and form trade unions;
    • vi. not use any compulsory or forced labor or take any part in human trafficking or in any other type of modern slavery; and
    • vii. treat all employees equally and with respect, regardless of race, color, religion, nationality, sex, political opinion, social origin or any other similar difference unless such differentiation is based on the ingrained requirements of the work in question.

 

4. OCCUPATIONAL HEALTH, SAFETY AND SECURITY

  • The Partner agrees to provide its employees and contractors with a safe, secure and healthy workplace in accordance with all applicable Rules.
  • Without limiting the generality of the foregoing, the Partner agrees as follows:
    • i. ensure that required health and safety information and equipment are provided to its employees and contractors;
    • ii. provide employees and contractors with necessities for a healthy working environment, including but not limited to clean drinking water, clean toilets and other facilities, proper lighting as well as required heating and/or air conditioning;
    • iii. ensure its relevant personnel is trained on product safety practices.

 

5. ENVIRONMENT AND CLIMATE CHANGE

  • The Partner shall take all reasonable efforts to protect the environment and to minimize the negative impact of its activities on the environment.
  • The Partner shall take a preventive approach to environmental challenges and take part in initiatives that promote greater environmental responsibility.
  • Without limiting the generality of the foregoing, the Partner agrees as follows:
    • i. obtain, keep current and follow all necessary environmental permits and/or approvals;
    • ii. follow to applicable environmental Rules of the jurisdiction(s) where the Partner operates;
    • iii. monitor, control and take actions on, according to applicable Rules, any emissions and waste or other negative environmental effects generated through its operations;
    • iv. always consider the environmental impact of its operations and undertake greenhouse gas reduction or other compensation measures where reasonable.

 

6. WHISTLEBLOWING

  • All our Partners should report any infringements of this Code directly to their contact person at EOS.
  • If the Partners are unwilling to make such report to their contact person, our Whistleblowing service offers a way for our Partners and their employees to communicate suspected wrongdoings of EOS through our anonymous notification channel. The notifications are protected under the EU’s Whistleblowing Directive, insofar they concern violations in fields of law specifically mentioned in the Whistleblowing Directive or the implementing national act.
  • Our notification channel is provided by a third party and the identity of sender of the notification is always anonymized. We handle all messages received through the channel in confidence only by appointed individuals. All personal data received through the notification is processed in accordance with the General Data Protection Regulation (”GDPR”).
  • Please note that no proof of wrongdoings is needed, but all notifications to the channel must be made in good faith.
  • To learn more about our Whistleblowing service, please see our Whistleblowing Guidelines: https://report.whistleb.com/en/eos

 

7. COMPLIANCE AND TERMINATION

  • The Partner agrees to regularly monitor compliance with this Code and shall upon request provide EOS access to all relevant documentation needed to demonstrate its compliance with the Code. EOS, or a third party chosen by us, has the right, with reasonable prior notice, to audit the Partner’s premises to validate compliance with this Code.
  • The Partner shall notify EOS promptly of any non-compliance with this Code.
  • The Partner acknowledges that a breach of this Code is a material breach and as such a sufficient ground for any EOS entity to terminate its agreements and business relationship with the Partner irrespective of the terms of any agreement to which this Code is attached.
  • Any products, which have been manufactured by or for the Partner in breach of this Code are deemed non-compliant, and EOS reserves the right to reject such products, without prejudice to any other remedies available to EOS under any Rules or agreements between the Partner and EOS.

 

8. APPLICABILITY

  • The obligations under this Supplier Code of Conduct are in addition to other obligations pursuant to any other contracts between EOS and the Partner.
  • The document can be signed independently or as an appendix of another agreement, such as a supply agreement.
  • This Code survives the termination or expiry of any other agreements to which it is attached and will remain in force in respect of any deliveries made by the Partner to EOS.
  • We constantly develop our compliance and sustainability processes. Therefore, we hold the right to update this Code unilaterally at any time. Upon significant updates, we shall deliver an up-to-date version of this Code to our Partners. We will inform you about updates via email and post the current status on our homepage.

 

9. ACKNOWLEDGEMENT AND APPROVAL

  • The Partner hereby confirms that it has carefully reviewed this Supplier Code of Conduct and will comply with its terms in full.
  • I, as the person signing this acknowledgement, have the authority to represent and bind the company identified below.

 

Code of Conduct

Whistleblowing guidelines

1. Introduction – what is whistleblowing, and why is it important?

Our organisation strives to achieve transparency and a high level of business ethics. Our whistleblowing service offers a possibility to alert the organisation about suspicions of misconduct in a confidential way. It is an important tool for reducing risks and maintaining trust in our operations by enabling us to detect and act on possible misconduct at an early stage. Whistleblowing can be done openly or anonymously.

 

2. When to blow the whistle?

The whistleblowing service can be used to alert us about serious risks of wrongdoing affecting people, our organisation, the society or the environment.

Reported issues include criminal offences, irregularities and violations or other actions in breach of EU or national laws within a work-related context, for example:

  • Corruption and financial irregularities; for example, bribes, unfair competition, money laundering, fraud, conflict of interest
  • Health and safety violations; for example, workplace health and safety, product safety, serious discrimination and harassments that are against the law
  • Environmental violations; for example, illegal treatment of hazardous waste
  • Privacy violations; for example, improper use of personal data

Employees are asked to contact their supervisor or manager for issues relating to dissatisfaction in the workplace or related matters, as these issues cannot be investigated in the scope of whistleblowing.

A person who blows the whistle does not need to have firm evidence for expressing a suspicion. However, deliberate reporting of false or malicious information is forbidden. Abuse of the whistleblowing service is a serious disciplinary offence. 

 

3. How to blow the whistle?

There are different ways to raise a concern:

  • Alternative 1: Contact a supervisor or manager within our organisation.  
  • Alternative 2: Anonymous or confidential messaging through the whistleblower reporting channel to the whistleblowing team: https://report.whistleb.com/en/eos

All messages received will be handled confidentially. The whistleblowing channel is administrated by WhistleB, an external service provider. All messages are encrypted. To ensure the anonymity of the person sending a message, WhistleB deletes all meta data, including IP addresses. The person sending the message also remains anonymous in the subsequent dialogue with responsible receivers of the report.

 

4. The investigation process

The whistleblowing team

Access to messages received through our whistleblowing channel is restricted to appointed individuals with the authority to handle whistleblowing cases. Their actions are logged and handling is confidential. When needed, individuals who can add expertise may be included in the investigation process, upon consent from the whistleblower in case identity of the reporting person is disclosed. These individuals can access relevant data and are also bound to confidentiality.

Receiving a message

Upon receiving a message, the whistleblowing team decides whether to accept or decline the message. If the message is accepted, appropriate measures for investigation will be taken, please see Investigation below.

The whistleblower will receive an acknowledgment of receipt of the report within 7 days.

The whistleblowing team may not investigate the reported misconduct if:

  • the alleged conduct is not reportable conduct under these Whistleblowing guidelines
  • the message has not been made in good faith or is malicious
  • there is insufficient information to allow for further investigation
  • the subject of the message has already been solved

If a message includes issues not covered by the scope of these Whistleblowing guidelines, the whistleblowing team should provide the reporting person with appropriate instructions.

The whistleblowing team will send appropriate feedback within 3 months upon the date of receiving the report.

Investigation

All messages are treated seriously and in accordance with these Whistleblowing guidelines. 

  • No one from the whistleblowing team, or anyone taking part in the investigation process, will attempt to identify the whistleblower.
  • The whistleblowing team can, when needed, submit follow-up questions via the channel for anonymous communication. 
  • A message will not be investigated by anyone who may be involved with or connected to the wrongdoing.
  • Whistleblowing messages are handled confidentially by the parties involved.
  • Corporate or external expertise may be included in the investigation upon consent from whistleblower.

 

5. Protection and privacy

Whistleblower protection

A person expressing genuine suspicion or misgiving according to these guidelines will not be at risk of losing their job or suffering any form of sanctions or personal disadvantages as a result. It does not matter if the whistleblower is mistaken, provided that he or she is acting in good faith.

Subject to considerations of the privacy of those against whom allegations have been made, and any other issues of confidentiality, a whistleblower will be kept informed of the outcomes of the investigation into the allegations.

In cases of alleged criminal offences, the non-anonymous whistleblower will be informed that his/her identity may need to be disclosed during judicial proceedings.

PROCESSING OF PERSONAL DATA

This whistleblowing service may collect personal data on the person specified in a message, the person submitting the message (if not sent anonymously) and any third person involved, in order to investigate facts on the declared misdeeds and inappropriate behaviour eligible under our code of conduct or internal rules. This processing is based on statutory obligations and the legitimate interest of the controller to prevent reputational risks and to promote an ethical business activity. The provided description and facts under this processing are only reserved to the competent and authorized persons who handles this information confidentially. You may exercise your rights of access, of rectification and of opposition, as well as of limited processing of your personal data in accordance with the local data protection legislation. These rights are subject to any overriding safeguarding measures required to prevent the destruction of evidence or other obstructions to the processing and investigation of the case. Data is stored within the EU. For any further questions or complaints please address your request to info@eos-sauna.de

DELETION OF DATA

Personal data included in a whistleblowing messages and investigation documentation is deleted when the investigation is complete, with the exception of when personal data must be maintained according to other applicable laws. Permanent deletion is carried out 30 days after completion of the investigation. Investigation documentation and whistleblower messages that are archived will be anonymised under GDPR; they will not include personal data through which persons can be directly or indirectly identified. 

PERSONAL DATA CONTROLLER:

EOS Saunatechnik GmbH is responsible for the personal data processed within the whistleblowing service.

PERSONAL DATA PROCESSOR:

WhistleB Whistleblowing Centre Ab (World Trade Centre, Klarabergsviadukten 70, SE-107 24 Stockholm) responsible for the whistleblowing application, including processing of encrypted data, such as whistleblowing messages. Neither WhistleB nor any sub-suppliers can decrypt and read messages. As such, neither WhistleB nor its sub-processors have access to readable content.