Mammoet's code of conduct

1. Safety 

Our customers and families depend on us to operate safely. At all times, safety comes first, for all involved. We believe in zero accidents at all times. Employees have the right and obligation to stop work that is unsafe or being done incorrectly. Therefore employees follow all methods of working, rules and precautions everywhere they work and wear the required Personal Protective Equipment. Loyalty means being ‘fit to work’ and ensuring your team members are as well, by avoiding substances or situations which might negatively influence performance. In order to keep our excellent reputation, we act on any unsafe situation, behavior or circumstance which can endanger the health or safety of any person.

 

2. Respect in all relationships

We all believe that respect is the key to successful and safe (work) relationships. We actively contribute to respectful environments where all cooperate as one team. Therefore each employee is expected to treat all others equally. We will recruit, hire and promote employees solely on the basis of their skills and capabilities which are relevant to the job. Employees avoid all forms of discrimination, such as discrimination based on gender, race, age, disability, sexual orientation, religion, belief, political opinion or social origin. They also refrain from behavior that may harm others, such as verbal or physical violence, harassment and intimidation. Employees should be free to express differing opinions and concerns without having to fear repercussions. Mammoet strictly prohibits any form of retaliation. A special policy on anti-retaliation has been developed in this respect to encouraging all employees of Mammoet to feel comfortable speaking up without fear of retaliation.  

 

3. Gifts, entertainment and our anti-bribery approach

Gifts and entertainment should be modest and appropriate at all times and used to strengthen business relationships, build goodwill and express gratitude. 'Appropriate' means that they are well-timed, moderate, infrequent, and not in excess of your local generally accepted business practices.

Gifts may never put pressure on the recipient to return a favor or influence the integrity of business decisions. The same applies to relations with government officials. This is particularly important as most government officials are not allowed to accept any gift or entertainment at all. In all cases, employees may only offer or accept gifts or entertainment in line with the law and policy of the recipient’s organization as well as our own policy. All forms of improper payment must be avoided.

Charity, sponsorships, or commission payments may never be used for the wrong purpose. Further details are described in our gifts and improper payments manual, which provides employees with practical advice on handling situations where something unusual or possibly improper occurs. We do not tolerate any form of bribery.

 

4. Conflicts of interests 

Working at a professional organization means that we work and act with objectivity, only in the best interests of Mammoet. We believe that business is business, and there is no place for secret, personal benefits, or commercial side activities. Employees are not allowed to use company information, resources, or their business position for personal gain. Sometimes your duty towards your employer may conflict with a more personal interest you might have towards family, friends, or even yourself. In these situations, employees should communicate in a transparent manner with their colleagues and managers. You are expected to be open and honest and avoid even the appearance of a possible conflict of interest and in such cases, withdraw from the business issue.  

 

5. Protecting company resources

Each employee is provided with a variety of company resources and is responsible for protecting these against loss, damage, misuse, and theft. Resources include vehicles, tools, and machines, but also our brands, innovations, intellectual property rights, and know-how. We use resources in a careful and professional manner, only for their intended business purpose. In exceptional cases, an authorized manager is the only person allowed to give you permission to use company resources for other purposes.

 

6. Protecting confidential information 

Employees make sure that all confidential information is preserved and protected in a professional manner. This applies to the confidential information of others as well as our own. Confidential information is information that can give a competitive advantage and/or is privacy related. You only reveal our company’s confidential information to anyone outside the company with proper protection. You respect and use confidential information of others (like our competitors) only in so far as you have a legal right to do so.

 

7. Protecting our ICT 

We can only continue our success when our ICT is correctly used and properly protected by all users. Incorrect use costs not only time and money, but it also creates various risks to employees and our company. To avoid these risks, we have created regulations governing the use of ICT resources and established control measures to ensure that our regulations are observed.

 

8. Correct information 

We conduct our business in a fair and honest way. We want to make business decisions based on all relevant facts. Therefore we need reliable data. Each employee has a duty to ensure that his/her financial and non-financial documents, records, and reports are accurate, complete, consistent, and up-to-date. The financial administration and supporting documents must accurately describe and reflect the nature of the underlying transactions. No secret or unregistered accounts, sums of money or assets will be established or held. We do not accept any form of fraudulent behavior like falsifying invoices or other documents, deceiving or misleading people, or helping illegal trade of any kind. Each employee is expected to prevent fraud within our company and is obliged to promptly report any suspicion of fraud or other violation of criminal law (like theft, fraud, bribery, competition laws and similar offenses).  

 

 9. Fair competition

We believe in competition based on fair play and a level playing field. The objective of competition law is to ensure fair and active competition between companies. We fully endorse this objective. You conduct all of your activities in a fair and competitive manner, thereby carefully complying with competition laws. Competitors must actively compete and take their own business decisions, not divide up markets, share prices, or similar sensitive business information like costs, bids, promotions, allowances, sales, suppliers, and terms and conditions of work. Employees must only use legally allowed sources of competitive information. To give employees a good idea of the rules that are relevant in certain situations, a special competition compliance manual has been issued, which is mandatory for employees in marketing, sales, and management positions.

 

10. Environment

Each employee commits to personally contributing to running our business in an environmentally sound and sustainable manner. We strive to minimize the adverse environmental impact of our processes and services. Together we contribute in this way to sustainable development without reducing the ability of future generations to meet their own needs. These policies and programs are an integrated part of our business. We monitor and report our sustainability performance annually in a transparent and consistent manner.  

 

11. Communications with third parties

Our employees ensure that their communication with outside parties is appropriate and accurate and in a manner that avoids damaging the reputation of our company. Employees are particularly careful not to speak to third parties such as the media about projects or work without prior approval. You are careful about writing and posting on any social media and internet site, platform, application, etc. which can be used to share with others such items as information, messages, opinions, photographs, and movies. Employees do not speak on behalf of Mammoet with the press or through social media unless they are explicitly authorized to do so. When approached by media, employees refer them to their regional Marketing Communication Advisor. They do not speak with the media unless they have been designated as a spokesperson.  

 

12. Trusted business partners 

We want to establish and maintain fair and jointly challenging relationships with reliable business partners who apply business conduct standards consistent with our own, who contribute to our goals and integrity commitments. Business partner relationships are evaluated consistently, with the objective of continuing improvements in all areas. 

 

13. Compliance - Laws & regulations and trade restrictions & customs

International trade restrictions prohibit us from engaging in certain business activities in certain countries and with certain persons, organizations and companies. These trade restrictions include prohibitions on interaction with identified terrorist organizations and boycotted persons and companies. International trade controls are designed to protect national and international security. We must also abide by certain special rules for transactions with governments. At Mammoet we all stick to the letter and spirit of the law at all times. We respect the immigration rules, import, export, customs and license restrictions and requirements everywhere we work. We conduct our activities in a fair manner. Before trading with potentially sensitive countries or companies, we double-check to make sure our plan is in compliance with all applicable (inter)national laws and regulations in this regard.  

 

14. Government investigations & proceedings 

Employees of Mammoet must cooperate with investigations, proceedings or raids from any legitimate local Government. A dawn raid is a surprise visit in which the visitors are legally authorized to enter premises, search for, copy and/or remove documents or other evidence and ask questions. Such raids may be organized by the national competition authorities, the European Commission, or various other governmental bodies. In order to help you in these cases, we have drafted a dawn raid manual. This manual provides instructions for different groups of employees who have different tasks in the event of a dawn raid.

 

15. Following the Mammoet code of conduct 

Managers have additional responsibilities

Of course, the Mammoet Code of Conduct also applies to all managers (including our Executive Board). Employees in management positions have increased responsibilities. Managers must implement the Mammoet Code of Conduct and its underlying policies and lead by example. A key responsibility is also creating an open environment so their employees can raise concerns or suspicions without fear of a negative reaction.

How to deal with dilemmas: the mirror test

If you are unsure about whether a course of action is acceptable according to our Code of Conduct and underlying policies you can do the mirror test. Look in the mirror and ask yourself these questions. It will help you to critically evaluate the action that you intend to take: Would I feel comfortable discussing this beforehand with my family and manager? Do I want to read about it in the newspaper? Do I accept full personal responsibility for this decision?

Raising questions or concerns

We expect each employee to support a culture of openness in which we all feel comfortable raising questions, dilemmas, and concerns related in any way to our Code of Conduct. We encourage you to discuss these with your colleagues or manager. If you are aware of a violation of the Mammoet Code of Conduct, you are encouraged to come forward. Also if you only suspect a violation or you only have a worry. If you feel that speaking up and discussing a suspicion with your manager is not reasonably possible, you can choose to report to your local Legal Advisor; the Human Capital department; or, if these are not easily reachable for you, as a last resort, see the Speak Up procedure for contacting the Alert line, available 24/7/365; if you just want to discuss a topic from the Mammoet Code of Conduct, please send an email to codeofconduct@Mammoet.com.

No negative effects

Demonstrating our company values, following our Code of Conduct and speaking up, all help to sustain our reputation and success. No employee will suffer if the business is turned down in order to follow our Code of Conduct. No employee will suffer if he or she has reported in good faith a suspicion of a violation of our Code of Conduct.

Sanctions

Disregarding or violating the law, our Code of Conduct or any of the underlying policies can have serious consequences for our company and the individuals involved. For example imprisonment, personal liability, and/or fines as well as reputational damage. Ignoring a violation can also have serious consequences. Using a third party or other methods to bypass the Mammoet Code of Conduct is prohibited. A violation may lead to disciplinary measures, including dismissal.