Code of Conduct

Introduction

 

Our company is one of the leaders in Europe for broadband internet and digital home solutions. Our products are easy to use and stand for innovation, dependability, and versatility: Whether for fast internet access, easy networking, powerful Wi-Fi, convenient telephony or clever smart home applications. Since 1986, we have been producing and developing our products in Berlin and manufacturing them in Europe. Our team of over 900 employees is the key to our success.

To continue our journey together and ensure the future viability of our company, one thing is essential above all else: mutual trust, which is achieved through responsible and ethical conduct. This is why our company is committed to consistently complying with applicable laws, norms, and standards. At the same time, we want to work together with all of our employees, customers, and partners to contribute to a sustainable world. For this, we focus on our innovative products and technologies that improve people's lives and protect natural resources.

This Code of Conduct translates our principles and values into clear guidelines for ethical and lawful behaviour. It serves as a guideline to help our employees make the right decisions in unclear and complex situations. That way we can minimize risks and prevent damage to the company. This makes it clear that we refrain from doing business that would only be possible by violating the law or internal corporate rules.

FRITZ! adheres to the laws, rules, and regulations of the countries in which it operates. The location of the company's headquarters means that German and European legislation form the basis of the Code of Conduct. Stricter guidelines or more detailed instructions may be implemented for certain regions, countries, or functions. Should any provision of the code conflict with local legislation, the provisions of the local legislation shall take precedence.

FRITZ!'s suppliers and their affiliated subsidiaries are required to commit to the principles of this Code of Conduct. They also commit to selecting all of their suppliers and subcontractors carefully, based on objective, factual criteria and in accordance with the principles of this Code of Conduct, to communicate these principles to them, and to ensure their compliance. We expect our employees and business partners to share the values set out in this Code of Conduct, and to commit to complying with them as well.

Jan Oetjen (CEO), Peter Faxel (CTO), Jan-Christian Werner (CFO)

Human Rights, Work Standards, and Social Standards

 

FRITZ! is committed to upholding the human rights of its employees and provides fair and favourable working conditions, including secure jobs, competitive pay, benefits, and regulated working hours. We create a safe and healthy working environment to help minimize work-related injuries and illnesses, while also enhancing employee satisfaction.

Secure jobs and adequate pay

FRITZ! offers secure, long-term positions with competitive pay and attractive additional benefits. The remuneration must comply with applicable pay laws, including those relating to minimum wage, overtime, and legally mandated social benefits. FRITZ! is committed to paying all of its employees a living wage, which it reviews regularly based on recognized benchmarks. We follow the principle of equal pay for equal work. Employees must promptly receive a clear and understandable payslip for each pay period. The use of temporary workers, the posting of workers, and the outsourcing of labour must all comply with the applicable legal regulations.

Regulated working hours

We offer flexible working hours that support a healthy work-life balance and accommodate family needs. The weekly working hours may not exceed the maximum number of hours permitted by local law. Including overtime, the weekly working hours may also not exceed 60 hours. Exceptions apply in emergencies and exceptional circumstances. Employees must be granted at least one day off for every seven days worked.

Freedom of association and dialogue

We respect our employees' right to form and join trade unions and interest groups, to participate in collective bargaining, and to hold assemblies. We value a culture of trust, where constructive dialogue and cooperation are encouraged, and where nobody is favoured or disadvantaged for participating in this. Employees and/or their representatives should feel free to communicate openly with management, without fear of discrimination, retaliation, intimidation, or harassment, and present ideas or raise concerns about working conditions and management practices. Our company's own model for an FRITZ! employee representative committee with its elected representatives provides a solid foundation for this and ensures a secure framework.

Antidiscrimination and equal opportunity

We treat everyone fairly, with respect, and without prejudice. We value diversity because it enables our teams to gain a better understanding of our customers in dynamic markets. Our guiding principles are equal opportunities and zero tolerance of discrimination. Employees, job applicants, and business partners must not be treated unfairly, favoured, disadvantaged or excluded on the basis of their race, ethnic origin, skin colour, gender, religion or belief, physical constitution, appearance, age, or sexual identity, or any other legally protected characteristic. Every form of harassment or bullying is prohibited. The Equal Opportunities Officer promotes relevant initiatives and monitors compliance across the entire Group.

Personnel development through training and further education

FRITZ! offers its employees excellent career opportunities and supports their professional development at every stage of their career. When embarking on their career, young people in Germany have a wide range of options available to them. These include internship programmes, theses collaborations, and dual study programmes. We ensure that our employees can fulfil their potential through regular training, customizable further education programmes, and a culture of mutual learning.

Health protection and occupational safety

In accordance with the applicable laws, regulations, and standards, we take all necessary measures to protect all employees and prevent work-related injuries and illnesses. Risk prevention and health promotion measures include, in particular, fire protection, personal protective equipment, emergency prevention and medical care, reporting of occupational illnesses and accidents, the safe use of machinery, and workplace ergonomics. Comprehensive training and instruction on health and safety in the workplace, along with clearly visible health and safety information throughout the company, play a key role. To ensure the health and safety of all employees, each employee must comply with the applicable laws, regulations, and standards for occupational safety in their workspace.

Protection of human rights

We treat all our employees at our locations, our businesses, and in their surroundings fairly, equally, and with respect. As an international company, we adhere to the principles of the International Bill of Human Rights, the OECD Guidelines for Multinational Enterprises, and the International Labour Organization's (ILO) work and social standards. Although all human rights are equally important, the following are of particular significance to us:

  • the right to equal opportunity and non-discrimination
  • the avoidance of all forms of child and forced labour
  • the right to freedom of association and collective bargaining
  • fair pay and benefits in line with local market conditions
  • compliance with applicable regulations on working hours.

Prohibition of child and forced labour

We ensure that any form of child labour, forced labour, or compulsory labour is excluded, and that we do not become complicit in human rights violations. This also applies to human trafficking, slavery in all its forms, involuntary prisoner labour, debt bondage, and other forms of forced labour. Employees' freedom of movement within the workplace must not be unduly restricted. They must be able to leave the workplace or terminate their employment at any time, in accordance with the contractual and legal notice periods. We condemn all forms of child labour and do not employ anyone below the minimum working age applicable in the respective country, which may never be lower than 15 years old. Employees under the age of 18 may not be permitted to perform hazardous work that could endanger their health and safety, including night shifts and overtime. FRITZ! also ensures that the employment of working students and interns complies with applicable laws and regulations.

Responsibility & Society

At FRITZ!, we base our daily activities on the pursuit of a long-term perspective. It therefore goes without saying that we take responsibility for the environmental compatibility and sustainability of our products, services, and locations. We are committed to reducing emissions, using resources sparingly, lowering energy consumption, and eliminating health risks. FRITZ!’s products offer our customers the highest levels of safety and quality.

Environment and resources

FRITZ! lays claim to be the innovation leader in the field of home internet access. This encompasses not only the performance and functionality of our products – we also adhere to the highest standards of environmental awareness. The environmental compatibility of our products is a top priority. As part of our quality management system, we are constantly improving our own products and manufacturing processes to prevent errors, reduce the consumption of energy and raw materials, and ensure that our products can be reused or disposed of in a resource-efficient manner. Through our actions, we aim to contribute to climate protection and consider the impact of greenhouse gas emissions associated with our business activities. To this end, we measure and analyse these emissions, taking targeted action in areas where this is relevant. Against this background, all employees are required to use resources such as energy, air, water, and land sparingly and in accordance with the relevant legislation. Waste must be disposed of in accordance with the relevant legislation. Wherever possible, hazardous substances must be replaced with safer alternatives. If this is not possible, measures must be taken to prevent the release of hazardous substances when these substances are handled, transported, stored, used, recycled, reused, or disposed of. Technical installations must be constructed, operated, modified, and extended in accordance with the applicable permit requirements. Furthermore, we recognise our responsibility for the sustainable design of our entire value chain. We therefore make every effort to ensure that our supply chain only sources and trades raw materials that do not originate from conflict regions where armed conflict is linked to human rights violations, child labour, and environmental destruction.

Product quality and product safety

For FRITZ!, ensuring high product quality is a key factor in the success of our business. We strive to achieve high customer satisfaction, avoid errors, and continuously improve our business processes. All business processes must comply with the applicable technical and legal standards and regulations. We pay particular attention to ensuring reliable and consistent compliance with regulations such as REACH and RoHS, which prohibit or restrict the use of certain substances in products and during manufacturing. Our products are everyday companions in many households and must therefore comply with all product safety requirements. All employees are responsible for minimizing any potential health and safety risks or hazards that may result from the use of our products, and must inform the relevant supervisors immediately if such issues arise. We consider the information security of our products to be an integral part of product quality. Our customers rely on the fact that our products will not unlawfully disclose or distribute any sensitive or protected information. We also consider the accessibility of our products to be part of FRITZ!'s quality promise. Our employees make sure that accessibility is considered right from the design stage, to guarantee that our products are fully accessible.

Governance & Ethics

 

Since its foundation, FRITZ! has built up a reputation as a reliable partner in both the business and consumer markets. Maintaining this reputation and ensuring long-term business success requires absolute integrity as well as ethically and legally compliant behaviour throughout our organization.

Dealing with conflicts of interest

We expect all employees to act in the company's best interests.  This means that business decisions at FRITZ! should be made without any conflicts of interest. Even the appearance of a conflict can harm the reputation of the individual and/or the company. Situations may arise in which FRITZ!'s interests do not (fully) align with those of an employee.  We aim to avoid such situations to ensure that decisions are made impartially and in the company's best interests. The responsible compliance officers have established specific procedures to prevent conflicts of interest, and even the appearance of such. These include the strict four-eyes principle outlined in the signature guideline, for example. However, if conflict situations do arise, they must be reported transparently to the relevant supervisor or the responsible compliance officer.

Corruption and bribery

Corruption generally involves demanding, accepting, offering or granting personal benefits in connection with a business activity or public office. Such benefits may take the form of a gift, an invitation or another favour, and may benefit either the individual or a third party, such as a family member. We are committed to fair competition for the benefit of our customers and other stakeholders. We also respect the independence of public officials. This is why FRITZ! prohibits any form of corruption, including so-called facilitation payments. These are payments made to a public official to initiate or expedite a routine government action to which one is legally entitled. Cash or cash-equivalent gifts are prohibited at FRITZ!.  Gifts such as presents and invitations are not uncommon in a professional environment. Particular attention must be paid to gifts that could lead to personal dependencies, feelings of obligation, or suspicion of bribery or corruption. The appropriateness of a gift is primarily determined by its financial value, the recipient's role and position, the timing in relation to negotiation and decision-making processes, and the business customs of the respective country. Where relevant, country-specific provisions are outlined in separate instructions. Gifts to related third parties, such as family members, are only permitted in exceptional cases that are clearly defined. FRITZ!'s anti-corruption policy explains and provides binding instructions to all employees on the avoidance of corruption.

Intellectual and company property

FRITZ! respects the patents, trade secrets, confidential business information, and know-how of its business partners. FRITZ! will not publish or disclose such information to third parties without explicit prior written consent from these business partners. All employees who deal with third-party business assets during business dealings are required to handle them carefully and not misuse them. Furthermore, we expect all employees to handle FRITZ!'s assets conscientiously, carefully, and responsibly. This includes both tangible assets such as company cars or IT equipment, and intangible assets such as company patents, licences, permits, certificates, and business information that is not publicly available.

Fair competition

We are fully committed to fair competition and to complying with all applicable antitrust and competition laws. Violations will not be tolerated and will result in sanctions. These rules must be strictly adhered to, especially when working with associations and interest groups. Even the appearance of any anti-competitive behaviour must be avoided. Our Antitrust Law Guidelines provide more detailed explanations of antitrust and competition law.  They offer all employees specific, binding instructions.

Responsible marketing

FRITZ! adheres to the principles of fair competition which protect the interests of customers and strengthen our long-term, trusting relationships with them. This way, FRITZ! can make verifiable product claims, offer transparent pricing and warranty policies, protect children and adolescents, avoid making unfair comparisons with competitors, and ensure compliance with all relevant data protection regulations relating to advertising.

Money laundering

FRITZ! complies with all legal obligations relating to the prevention of money laundering. We do not engage in money laundering activities. Management must be informed immediately in the event of any unusual financial transactions that could raise suspicions of money laundering activities or other doubts about the legality of transactions. FRITZ! does not accept or make cash payments, except where the sums involved are negligible. All other payments must comply with tax laws, and with anti-money laundering and anti-corruption regulations.

Embargo laws and trade sanctions

FRITZ!'s international business activities may be affected by applicable trade sanctions and embargo laws. Embargo laws and regulations generally prohibit companies based in one country from conducting business in certain other countries.  The companies and all of their employees are obliged to comply with all applicable laws, rules, and regulations relating to embargo laws and trade sanctions at all times. FRITZ! monitors the compliance with these embargoes and sanctions.

Data protection

Protecting data, assets, employees, visitors, information systems, premises, and telecommunications networks from hostile actions and, if necessary, competitors is of the utmost importance to our success. Any kind of confidential information such as trade secrets, inventions, designs, sketches, technical or economic information must not be disclosed to unauthorised persons within or outside the company. This obligation continues even after the end of an employment relationship. To protect such information, this confidentiality agreement must also be included in contracts with our business partners. With regard to protecting private information, FRITZ! is committed to meeting the reasonable expectations of its business partners, including suppliers, customers, consumers, and employees. When collecting, storing, processing, transmitting, and sharing personal information, applicable data protection and information security laws (e.g., the General Data Protection Regulation) and government regulations must be observed. Additional and more specific information on this topic can be found in our company-wide data protection notices.

Accounting and documentation

The successful operation of FRITZ!'s business and the integrity of its information also depend on the completeness and accuracy of the company's business records, and on the transparent and reliable disclosure of related information. Therefore, all relevant paper and electronic records must be maintained accurately and in compliance with applicable laws and with FRITZ!'s data retention policies, including the relevant retention periods. No false or misleading entries may be made in FRITZ!'s books, records or accounts. Company funds may only be used for the purposes stated in the relevant documentation.

Rules for external communication

Employees who comment publicly on FRITZ!, including on social media, influence how our company is perceived by stakeholders such as customers, the media, business partners, job applicants, and capital market participants. Therefore, when employees express personal opinions in public, it must be clear that these are not the views of FRITZ!. This applies in particular to social media. Only authorised individuals are permitted to make official statements on behalf of FRITZ!.