Code of Conduct

We are Lumibit.

We provide development services in automotive, digital processes, and tools – delivering first-class technical solutions with an uncompromising commitment to innovation.

We define our fundamental values in this Code of Conduct, which applies equally to all employees and managers.

We expect them to respect the values and principles described here and to integrate them into their daily work.

This also applies to our suppliers, with whom we maintain business relationships only on the basis of, and in compliance with, the standards described here.

Corporate Principles

Protection of Human Rights

The explicit protection of human rights within our sphere of influence is the foundation of our corporate conduct.

Our company will not participate in human rights violations in any form, whether directly or indirectly.

We expect our partners and suppliers to fully respect human rights and to treat all people fairly and with respect.

Freedom of Association and the Right to Collective Bargaining

We respect employees' right to collective bargaining and freedom of association.

At Lumibit, every employee is free to join, form, organize, or participate as a member in employee representation bodies. We commit to ensuring that no employee suffers any disadvantage as a result of such membership or of belonging to a trade union. Employee representatives may conclude and negotiate company agreements, collective bargaining agreements, and other operational agreements at the appropriate levels.

We expect our suppliers to respect employees' right to freedom of association and the right to collective bargaining.

Commitment to Fair Working Conditions

Fair working conditions apply across our company to all employees, in all business processes and in the delivery of our services.

We consistently comply with existing (national) regulations on working hours and commit to fair and appropriate remuneration. To this end, we adhere to statutory minimum standards, minimum wages, and any applicable collective bargaining agreements where these apply to the relevant business area.

Agreed salaries that are subject to nationally mandated social security contributions are borne by our company and paid to the relevant authorities.

Our employees are our greatest asset, which is why we are committed to their ongoing qualification and professional development.

We expect these same requirements – fair working conditions, ongoing professional development, and the appropriate treatment and remuneration of employees – from our suppliers as well.

Elimination of All Forms of Forced Labor, Child Labor, and Human Trafficking

Lumibit is firmly committed to the prohibition of any form of forced labor. This includes the provision of services and work imposed on individuals under the threat of punishment or other coercive measures, such that those individuals would not perform them voluntarily.

We likewise require our suppliers to commit to the prohibition of forced labor.

Furthermore, Lumibit expressly commits to the:

  • Prohibition of any form of child labor
  • Prohibition of any form of human trafficking

We expressly require our suppliers to tolerate no form of child labor or human trafficking within their companies or value chains. As within our own company, we expect our suppliers to ensure that young employees do not carry out work of a particularly hazardous nature, and that applicable regulations on the employment of minors are observed at all levels. Furthermore, such employment must not prevent young employees from pursuing a qualified education.

Elimination of All Forms of Discrimination in Employment and Occupation

Lumibit rejects discrimination in any form within the employment environment. Our employees enjoy a right to privacy that we respect unreservedly, including in the workplace.

We are committed to equal opportunity and diversity in our corporate culture. Employment-related decisions (e.g., hiring, promotions, professional development, training, internships) are made solely on the basis of individuals' skills and qualifications, with transparent processes and requirements.

These decisions are not influenced by ethnic origin, social background, disability, age, gender, religion or belief, nationality, sexual identity, trade union membership, or personal relationships.

We firmly reject sexual discrimination or harassment in any form, regardless of the groups or genders involved, and will take appropriate legal action against it.

We likewise expect our suppliers to commit to diversity and equal opportunity, as well as to the uncompromising enforcement of prohibitions on discrimination and harassment.

Occupational Health and Safety

National laws on occupational safety and health protection are fully observed within our company.

It is our declared goal to provide all employees with a safe working environment and to protect their health by every available means. To this end, our company pursues measures to reduce individual risks to which employees may be exposed during their employment. This includes, in particular, health protection and measures to prevent accidents.

Our working conditions are designed to meet employees' needs and are subject to a process of continuous improvement. Statutory requirements relating to health protection, workplace ergonomics, and occupational safety are fully observed within our company.

We require our suppliers likewise to comply with national legislation and minimum standards on occupational safety and health protection. This includes taking active measures to prevent accidents, illness, and death, and to provide employees with a safe working environment.

Environmental Protection and Use of Resources

Our company places great importance on keeping environmental risks and negative impacts on our surroundings as low as possible. Through appropriate measures, we focus in particular on:

  • Responsible handling and active management of natural resources
  • Avoiding or reducing waste and actively managing sustainable resources
  • Measures to preserve water quality and use water sparingly
  • Very careful handling of chemicals
  • Keeping the air clean
  • Reducing greenhouse gases
  • Reducing energy consumption
  • Using renewable energy in our products and services
  • Preferring to work with suppliers that produce on a climate-neutral basis and using renewable energy, both domestically and abroad

We observe and consistently implement national environmental laws and standards, and we extend this same requirement to our suppliers and partners. The use of efficient, modern, and environmentally friendly technologies holds high importance in our company, and we expect the same from our suppliers.

We require our suppliers to avoid causing any preventable environmental damage.

We commit to respecting land, forest, and water rights, and to ensuring that forced evictions are avoided in all activities and that the rights of local communities are upheld.

Combating Corruption, Extortion, and Bribery

Our company fully rejects corruption, bribery, and extortion in any form or expression, and takes all appropriate measures to prevent them. Improper benefits and payments (e.g., in the form of cash, benefits in kind, or other forms of personal advantage) must not influence our own or others' decision-making processes. In general, conflicts of interest are to be avoided and disclosed. We commit to ensuring that affected individuals and employees suffer no disadvantage as a result of such disclosure.

We require our suppliers to act consistently against all forms of corruption and personal advantage-taking, and to refrain from unfair competition. Suppliers must neither accept bribes nor engage in bribery themselves. Furthermore, we require our suppliers not to participate in price-fixing and not to enter into unfair agreements with competitors.

Our company does not participate in cartels or other forms of collusion to obtain disproportionate advantages, and lives by free and fair competition.

Protection of Intellectual Property

We protect the intellectual property of our customers, employees, and suppliers using appropriate technical and organizational means and measures.

We keep our value-creation process free of plagiarism, counterfeit products, and counterfeit software, and, as part of our quality assurance, we ensure that no counterfeit products are placed on the market.

Compliance with Data Protection and Information Security Requirements

When processing personal data, we comply with all statutory data protection requirements and regulations, and we require the same of our interface partners.

We carefully address requirements relating to information security in general, to commissioned data processing, and to the processing of information belonging to our customers, employees, and suppliers, and we consistently implement appropriate technical and organizational measures.

Principle of Financial Responsibility

All material business transactions are documented by us in a traceable and timely manner.

External and internal reports (e.g., on financial accounts, quality, time records, billing, or other economically relevant documents) are maintained, archived, and made available to relevant interface partners by us in full and without gaps.

Documents required for ongoing or anticipated internal inquiries or official investigations are neither destroyed, removed, nor altered by our company or our employees.

In accordance with applicable law, financial records are prepared in line with generally accepted accounting principles. Our company assumes (financial) responsibility for this.

Information is disclosed by our company in accordance with applicable regulations or the customary practices of our industry. This includes:

  • Occupational safety measures
  • Environmental practices
  • Business activities
  • The company's financial situation

This information is disclosed to the relevant groups of individuals or employees through common methods of publication.

General Requirements

This Code of Conduct sets out our minimum standards, the observance of which we expect from all employees and from our suppliers.

In our business activities, we presuppose the application of national laws, regulations, and provisions, and we comply with applicable customs, export, and sanctions regulations.

We fully observe international legal requirements and restrictions on export controls and export restrictions concerning security-relevant services and goods.

We require our suppliers to pass on all requirements of the relevant sections of our Code of Conduct to any sub-suppliers and subcontractors, and to ensure that these are met by them.

Compliance with the Code of Conduct

We will respond to any violations of applicable laws, breaches of established standards, and breaches of this Code of Conduct by taking measures under labor law or by terminating business relationships.

Complaints Procedure and Whistleblower Policy

Our company has established a complaints process for our employees and external parties. Anonymous reports can be submitted to the email address csr@lumibit.io, or in postal form addressed to the management with the note "personal/confidential."

For any reports and incidents, we guarantee the anonymity of the reporting person and confidentiality. Whistleblowers are protected against retaliation or reprisals.