Hello,

We, CFP Brands Süßwarenhandels GmbH & Co KG (hereinafter referred to as CFP), as a modern company, are committed to ecologically and socially responsible corporate governance. We always act in accordance with the relevant legal requirements and in line with our corporate values.

In addition to professional performance, legally compliant and responsible behavior of the management, executives and all employees (hereinafter collectively referred to as employees) is an essential basis for successful business activities. The management and executives are aware of their special role model function.

Our five "mindsets" serve as guidelines for the behavior of all employees, especially when dealing with this Code of Conduct:

  1. Every employee feels responsible for what he/she does (I OWN IT).
  2. We always try to master challenges successfully (WE PLAY TO WIN).
  3. The actions of each individual employee influence the success of our organization (I CAN MAKE A DIFFERENCE).
  4. Every employee learns and grows every day (I CAN GET BETTER EVERY DAY).
  5. Every employee puts things into practice and does not get lost in theory (EXECUTION IS KING).

This Code of Conduct is intended to help us implement the legal requirements and our corporate values in our daily work. It applies (for an indefinite period of time) to all employees and to all areas and activities of CFP.

We expect our business partners to adopt a similar approach to the implementation of corporate values.

Yours sincerely,
Fabian Röcke

I. Integrity and Compliance

  1. Compliance with the law and internal guidelines
    We expect our employees to strictly adhere to this Code of Conduct as well as to any specific compliance guidelines or instructions (including those that may be issued in the future) to specify particularly important topics.
    The regulations of this Code of Conduct represent a minimum standard. As far as legal requirements or internal procedural instructions stipulate stricter requirements, these take precedence over the Code of Conduct and must be observed accordingly.
    Violations of the law, this Code of Conduct, internal guidelines or instructions can have serious consequences for individuals, but also for CFP. In particular, they may result in fines or prison sentences.
    Such violations will not be tolerated by us and may lead to sanctions against the persons concerned (including measures under labor law, such as dismissal). This also applies if the misconduct is supposedly in the best interests of the company.

  2. Prevention of active and passive corruption
    We explicitly reject any form of corrupt behavior and avoid even the mere appearance of such behavior.
    Our employees must not offer, promise or grant any benefit to business partners in Germany or abroad in order to gain a competitive advantage. Similarly, they must not demand, be promised or accept any benefits from business partners in order to favor them in competition.
    It does not matter whether such a benefit is of a material nature (e.g. in the case of gifts or an invitation to an event) or of a purely immaterial nature (e.g. in the case of the awarding of honorary posts).
    When dealing with public officials, stricter legal requirements apply, which must also be observed. Therefore, no benefits may be granted to public officials.
    In particular, no "facilitation payments" must be made in this respect. This term covers payments that are not required by law in order to induce a public official to perform an act to which CFP is entitled within a shorter period of time.
    Public officials include public servants and employees of public authorities, but also employees of companies that are owned or controlled by the state.
    The prohibition of corruption must also be observed in the context of donations and sponsoring measures. Donations and sponsoring measures must therefore always be agreed with the management.

  3. Fair competition
    We are committed to free and fair competition in our business activities. We compete successfully through innovation and the quality of our products and services. We expect our employees to comply with the applicable competition and antitrust regulations.
    In this respect, we advertise and market our products and services truthfully and in accordance with the relevant laws.
    Furthermore, it must be ensured in particular that no prohibited agreements restricting competition are made with competitors, customers (especially retailers) and suppliers – for example on prices or sales conditions, market/customer/territory or production allocations. The same applies to concerted practices, in particular through the exchange of competitively relevant information with competitors. Instead, business decisions are always made independently and autonomously.

  4. Avoidance of conflicts of interest
    It is the duty of employees to make business decisions only in the best interests of the company and uninfluenced by possible personal benefits or considerations (such as the interests of employees, their family or friends). Conflicts between private interests and the interests of the company must be avoided.
    Such conflicts may arise, for example, if employees or persons close to them work for or hold shares in a company having a business relationship or competing with CFP.
    In the event of a conflict of interest and in cases of doubt, it is the duty of employees to inform the HR department immediately and to comply with their decision in the further course of action.

  5. Money laundering prevention and trade controls
    Money laundering describes the process of smuggling illegally generated money or illegally acquired assets into the legal financial and economic cycle.
    We act in accordance with the legal requirements for combating money laundering and terrorist financing and therefore take appropriate measures to ensure that funds received originate only from legitimate sources. Every employee is obliged to inform the Financial Control & Accounting Leader immediately if there are any indications of payments from illegal sources and to comply with his/her decision. The same applies in the event of other doubts about the permissibility of payments (e.g. in the case of irregular payment transactions).
    We also comply with the applicable legal requirements for trade control (including requirements for imports and exports).

  6. Data protection and information security
    We are aware of the importance of data protection and information security. The protection of personal data of employees, customers and other business partners is of outstanding importance to us.
    The collection and processing of this personal data is in accordance with legal requirements and takes account of fundamental principles such as lawfulness and transparency, data minimization and purpose limitation. In this respect, we do not only take technical and organizational measures to achieve the highest possible level of data protection and information security. In particular, all employees are also obliged to act in accordance with the applicable laws and regulations on data protection and information security.

  7. Protection of company property and business secrets
    Our employees treat material company property (such as computers or office equipment) and immaterial company property (such as software and know-how) responsibly and with care. Company property may only be used in accordance with its authorized purpose. Employees must not use company property for their own, inappropriate or unauthorized purposes.
    In this respect, the protection of our business secrets (such as know-how, customer data or price calculations) is of outstanding importance and a requirement for our economic success. This protection is ensured in particular through suitable technical and organizational measures as well as process and contractual arrangements. We expect our employees to treat confidential information and business documents (whether from the company itself or from our business partners) as strictly confidential and to protect them in an appropriate manner against disclosure and unauthorized access by third parties.

  8. Accounting and documentation
    All books and records of business transactions must be kept and archived correctly and transparently in compliance with both legal requirements and internal guidelines.

II. Compliance with Human Rights (also in the supply chain)

Respect for human rights is of particular concern to us, which is why we are committed to protecting human rights in accordance with the United Nations Universal Declaration of Human Rights.

  1. No forced or child labor
    We do not tolerate any form of forced or child labor.

  2. Freedom of association and collective bargaining
    We respect the right of our employees to freedom of association, freedom of assembly and collective bargaining in accordance with applicable law. Under no circumstances will our employees be sanctioned or discriminated against in any way because of their decision to join or not to join an employee representative body.

  3. Prohibition of discrimination and fair wages and working hours
    We do not tolerate any form of discrimination, whether based on gender, ethnic origin, religion, age, disability, nationality, sexual orientation, socio-economic class or any other characteristic protected by law. Physical punishment, harassment of any kind, psychological or physical attacks, verbal abuse or abuse of power are strictly prohibited.
    We pay fair wages and provide benefits that are at least equivalent to the statutory minimum wages and benefits applicable at the place of employment. Female and male employees receive equal pay for equal work.
    We respect the applicable working time regulations.

  4. Health and safety in the workplace
    It is particularly important to us to maintain the safety and health of our employees. Only such behavior leads to sustainable economic success. Accordingly, we organize our operational processes and the working environment properly and in accordance with the applicable health and safety laws.
    Employees must also promote this goal and comply with occupational health and safety regulations.

  5. Conservation of natural resources
    We respect the legal requirements regarding the environment (specifically land, forests and water) and are committed to the careful use of natural resources.

III. Implementation of the Code of Conduct

  1. Behavior in case of doubt/questions
    If there are any doubts/questions as to whether a certain behavior is permissible, the behavior must be refrained from until further notice and the management must be contacted. The decision of the management must be observed.

  2. Voluntary participation
    All of our employees are encouraged to report any legal violations or dubious business transactions that they perceive in their working environment in relation to another person. This may, for example, be a suspicion of corrupt behaviour.
    A report can be made via an electronic whistleblower system (integrated in HR Lab), by e-mail, by telephone or in person as follows:

    This Code of Conduct does not oblige anyone to report such information. However, any legal, contractual or other obligations or duties to report such information remain unaffected.
    We assure our employees that no employee who reports possible misconduct by other persons in good faith on the basis of concrete evidence will face any disadvantages on the part of CFP. This also applies, of course, if it subsequently appears that there was no misconduct.

  3. Expectations towards our business partners
    In our relationships with our business partners, we strive for a performance-oriented, value-added long-term cooperation with sustainable development prospects. This is why we behave loyally and in a spirit of partnership towards our business partners.
    We expect the same from our business partners, also with regard to the application of at least equivalent codes of conduct. We also encourage them to enforce the contents of this Code of Conduct in their supply chains.
    We reserve the right to review the application of at least equivalent codes of conduct by our business partners on a regular and ad hoc basis.
    If doubts remain in this respect with regard to compliance with at least equivalent codes of conduct, we contact our business partners to take appropriate countermeasures. If necessary, the cooperation will be terminated.
    Rights in favor of third parties shall not be established by the above expectations.

Düsseldorf, im Januar 2025
Fabian Röcke

Address: Kaistraße 5, 40221 Düsseldorf
Telephone: 0211/311113-0
E-mail: info@cfp-brands.de