Foreword

At GlobalPath Germany, integrity, transparency, and responsibility form the basis of our business activities. Our success depends not only on the quality of our work, but also on treating each other, our customers, partners, and society with respect and responsibility. We promote a working environment in which ethics, transparency, dignity, fairness, and responsibility are respected. 

Scope of Application

This Code of Conduct covers both our own business activities and our supply chain. It applies to all employees, managers, suppliers, and partners of GlobalPath Germany and helps us to live our values in our daily work. It describes how we should treat each other and others and provides guidelines for responsible behavior.

Our Commitment

We are committed to complying with ethical and human rights standards, fair recruitment principles, and all legal requirements in the countries in which we operate. 

Respect for Human Rights

We are committed to complying with international human rights based on international human rights agreements and the UN Guiding Principles on Business and Human Rights (UNGPs). This commitment includes, in particular, international labor rights as enshrined in the core labor standards of the International Labor Organization (ILO). We regard these standards as minimum requirements. We strive to exceed these standards in our area of responsibility and to continuously improve them. 

Key Human Rights Topics

Human rights violations including discrimination, modern slavery, forced labor, abuse, exploitation, human trafficking, child labor, and any form of harassment and unfair treatment are prohibited.

Prohibition of discrimination

We foster a respectful, inclusive, and appreciative work environment. Any form of discrimination, whether based on gender, ethnic origin, skin color, religion or belief, disability, age, sexual orientation, gender identity, or other characteristics protected by law, will not be tolerated. We expect all employees, managers, and business partners to act in a manner that promotes diversity, ensures equal opportunities, and maintains mutual respect.

Prohibition of Forced Labor and all Forms of Modern Slavery 

All forms of modern slavery, forced labor, human trafficking, and child labor are prohibited.

Work is performed exclusively on a voluntary basis, and employees are free to decide on their employment conditions. The use of forced labor, including but not limited to debt bondage, serfdom, bonded labor, and involuntary prison labor, is prohibited. Workers' freedom of movement must be respected, and all practices that could restrict this, such as physical restraints or the retention of workers' original identity documents, are prohibited.

We expect our partners, employers, and suppliers to adhere to the same high standards. Any indications of forced labor, child labor, or other forms of modern slavery will be investigated and will result in consistent measures, up to and including the termination of business relationships. 

Fair working conditions 

All employees have the right to fair working conditions. All applicable labor laws and internationally recognized labor standards, including fair remuneration, regulated working hours, safe working environments, and the right to rest, must be observed. Wages and salaries are paid transparently, on time, and at least in accordance with legal or collective agreement requirements. 

We only cooperate with employers, suppliers, and partners who share these principles and are able to guarantee fair working conditions for their employees.

Occupational Health & Safety 

We attach the utmost importance to the safety and health of all employees. We create safe working environments and take measures to identify, prevent, minimize, or eliminate potential hazards. This includes compliance with all relevant laws, regulations, and standards in the area of occupational safety. We also expect our partners to actively promote occupational safety and implement appropriate protective measures for their employees. Every employee is required to report safety-related risks and comply with applicable safety rules so that we can work together to ensure a healthy and safe working environment.

Freedom of Association 

We respect the right of all employees to freely organize, join unions, form works councils, or use other forms of representation within the framework of applicable laws. We expect our business partners to uphold these rights as well and not to discriminate against or pressure their employees when they exercise their right to freedom of association. Dialogue, constructive cooperation, and mutual respect between employers and employee representatives are central principles of our business practice.

Voluntary Participation and Transparency in the Recruitment Process

Recruitment is exclusively voluntary. All candidates receive complete, truthful, and understandable information about working conditions, contracts, costs, and rights before signing any agreements. Candidates are informed about their rights and about internal and external complaint channels.

Prohibition of Corruption 

We pursue a zero-tolerance policy toward all forms of corruption, bribery, and unfair advantages. Employees and partners may not directly or indirectly offer, accept, or demand payments, gifts, or other benefits in order to influence business decisions. We act in accordance with all applicable anti-corruption laws and guidelines. Our business relationships are based on integrity, fairness, and transparency. Suspected cases of corruption must be reported immediately to the relevant internal departments and will be thoroughly investigated. 

Risk Analysis 

We conduct annual and event-driven risk analyses to identify potential human rights, labor law, environmental, and compliance-related risks in our own business processes and in our supply chain. The aim is to identify risks at an early stage, assess their probability of occurrence and impact, and take appropriate measures to avoid or mitigate them.

Corrective and Preventive Measures 

If risks or violations are identified, we take appropriate corrective or preventive measures to avoid, minimize, or eliminate them. We also expect our business partners to cooperate with us in implementing appropriate measures to avoid, minimize, or eliminate identified risks or violations.

Integration

We promote the linguistic, cultural, and professional integration of skilled workers in Germany.

Complaint Mechanism

Violations of this Code of Conduct and applicable legal requirements and standards can be reported confidentially via our reporting channel EthicsVoice. We encourage all customers, employees, partners, and other stakeholders to report observed or suspected violations without fear of discrimination or reprisals. Every report is treated confidentially, taken seriously, and carefully investigated.

Continuous Improvement

We shall monitor and review our policies and due diligence processes at least once a year and make updates where necessary to ensure that they remain relevant and effective.