The CITO GROUP’s Code of Conduct

A. Preamble

We have established this Code of Conduct in order to safeguard our independence and in order to fulfil our responsibility as a company. The CITO Code of Conduct is a self-imposed obligation on the part of all employees to behave fairly and responsibly in their daily professional lives. We wish to be a partner for our business associates who acts in a transparent, responsible and ethically correct manner for which this Code of Conduct establishes an appropriate behavioural framework. For the sake of legibility, the masculine form is always used, whereby both male and female employees are meant.

B. Scope of application

The Code of Conduct applies to all companies in the CITO-Group, both at home and internationally (abbreviated to “CITO”) as well as to all employees, irrespective of their function and position in the company hierarchy.

National law will have precedence should it in individual cases stipulate stricter rules than the principles laid down here. Managers have a particular function as role models with regard to compliance with the Code of Conduct.

1. Compliance with the laws

We undertake to comply with all laws and regulations applicable to us, both domestically and in the European Union (EU), as well as conventions of the International Labour Organisation (ILO) and the United Nations (UNO). Provided that they deal with the same sets of circumstances, those rules stipulating the strictest requirements will apply. Our employees are required to conform to the following principles, which may not be circumvented by any other agreements.

2. Corruption and bribery

The interests of the CITO-Group and the private interests of its employees on both sides must be strictly separated in dealings with customers, suppliers and service providers as well as with government institutions. Actions and decisions must always be taken free of any extraneous considerations and personal interests, i.e. benefits-in-kind may not be accepted in return for showing preferential treatment in business relationships.

For their part, our employees undertake not to offer or to demand any gifts, payments, services or invitations that could influence a business relationship in a manner that is not legitimate.

3. Export trade regulations, conflict minerals

CITO does not supply products or services, either directly or indirectly, to countries for which international trading sanctions exist. At present, these are North Korea, Syria, Cuba and Iran as well as the Crimea/Sevastopol and Donbass regions of Ukraine. We obtain the necessary export licences for products that have a so-called “dual use”.

CITO or our sales partners make regular background checks of actual and potential customers against the applicable sanctions lists (at least those of the UN, EU, USA and the respective export country), whereby our sales partners at least comply with equivalent rules to these.

Our products do not contain any conflict minerals (e.g. tin, tungsten, tantalum, gold).

3. Accounting

The use of resources within CITO is only permissible provided that the relevant transactions have been properly booked. Payment applications may be submitted and payments made solely in the interests of the Group. Transactions carried out must correspond with the appropriate accounting documents.

4. Competition law

We rely on fair competition with other players in the market. We expect that our employees and individuals appointed to represent CITO comply with all applicable domestic, EU and international anti-trust laws. Agreements that influence prices or conditions or other measures that improperly impede free competition are forbidden.

5. Data protection

We undertake that communication will be confidential and transparent. We undertake to safeguard operating and company secrets.   Confidential information may not be disclosed to third parties or stored on external data media or forwarded to private e‑mail accounts, unless approval has been expressly granted that this may be done.  Confidential information may only be disclosed externally provided that this takes place due to provisions of the law or a court order. The obligation to maintain secrecy will remain in force after employment has ended.

6. Occupational safety and health

We take all necessary measures in order to avoid accidents and dangers to health arising in connection with the employee’s work. We undertake to subject the place of work to continuous improvement. We expect employees to use their own initiative in maintaining their health and support them in maintaining and developing a style of living that is conducive to health. Against this background, the consumption of alcohol, drugs or other narcotics during working time is forbidden.

7. Working time

We undertake to comply with the relevant provisions of the law and operating standards governing working time and public holidays. 

8. Remuneration

Remuneration at CITO is oriented towards standards set by the law and our operations. Employees receive clear and regular information on the composition of remuneration.

9. Employees’ rights

We respect our employees’ right to organise and their right of assembly. We give an assurance that employees who commit themselves in this way will not have to anticipate any negative consequences. 

10. Employment of children and young people

CITO is committed to respect for the rights of young people. CITO will not tolerate any kind of exploitation of children and young people whatsoever. Child labour within the meaning of ILO conventions and the United Nations as well as domestic regulations is forbidden. The age limit for permitted employment may not lie below the age of compulsory education and under no circumstances below 15 years of age. Young people may not be subjected to any dangerous or unsafe situations or situations injurious to health.

11. Forced labour

CITO rejects any form of forced labour. In conformity to ILO conventions, all forms of forced labour and work in contravention of human rights is forbidden. 

12. Advancement of employees

In accordance with our management philosophy, we practice values of openness to development, focus on performance and respect. We promote the personal development of the individual. To this end, we carry out appropriate personnel development and further training programmes and enable employees to identify with the company. On the other hand, we expect from our employees openness and a willingness to take on responsibility and to develop further.

13. Equality of opportunity

CITO is committed to fairness and respect in dealing with others. Any form of victimisation and verbal, physical and/or sexual harassment and/or pressure will not be tolerated. We are also committed to opposing any kind of discrimination that must be avoided at the time of the appointment of the employee and during employment. Any distinction on grounds of 

  • Ethnic, national and social origin
  • Race
  • Colour of skin
  • Sex
  • Age
  • Nationality
  • Religious affiliation
  • Political opinions
  • Physical or mental handicap
  • Sexual orientation

or other personal characteristics is forbidden

14. Environmental protection

We undertake to comply with the applicable laws and minimum requirements with respect to the protection of the climate and the environment. Our employees treat natural resources with care. Environmentally conscious behaviour signifies for us:

  • Efficient use of resources (energy, water, raw materials, the air)
  • Use of environmentally friendly materials
  • No use of illegal materials (e.g. wood acquired illegally)
  • Avoidance of emissions and waste materials
  • Establishment of management systems to protect resources

15. Communication

This Code of Conduct is accessible to all CITO employees and is provided in the relevant national language. It may also be viewed in the Internet under

C. Complaints procedure

We expect that all employees will act responsibly in the spirit of this Code of Conduct. In the event of a justified suspicion that the Code of Conduct has been infringed, the employee is free to refer to the board of management or to the employees’ elected representatives. Employees who in good faith suspect misconduct do not have to fear any negative consequences. The complaints procedure may not however be used to spread stories or information that is knowingly false. Any infringements are reported in a manner that guarantees anonymity.  

D. Sanctions

Depending on the gravity of the infringement, CITO reserves the right to initiate disciplinary and/or legal measures.

Schwaig, March 2020