Code of Conduct

1. Our “compass” questions

The rules of the Code of Conduct form the basis for our decisions, which are characterized by respect and integrity. At the same time, we strictly comply with the law. Therefore, we are always called upon to apply our good judgement to our business decisions as well as thoroughly consider and critically scrutinize our decisions.

We should always be able to answer “Yes” to the following questions. These questions also serve as aids for making decisions in situations where it isn’t immediately clear which specific behavior is required.

- Do I feel good about my decision because I assume that it complies with legal and in-house requirements?

- Have I gathered all the relevant information about the effects of my decision, taken everything into account, and carefully weighed all the factors?

- Do people outside gmp perceive my behavior as humanely and ethically correct?

- Would I approve if another person behaved in exactly the same way and if gmp were my own company?

- Could I stand behind my decision with a good conscience if it were reported in the news?

If you can’t answer a definite “Yes!” to all these questions or if you have other doubts, seek advice².

2. gmp as shapers of the future

As architects, we help shape the future. We’re aware of our particular responsibility for the environment and humanity. This being the case, we have been UN Global Compact signatories since 2020 (for more information, visit: gmp Architekten | UN Global Compact). We share and promote its goals.

2.1. Respectful conduct

Architecture is an art that is highly dependent on the dialogue with other people and organizations throughout the design and structural implementation phases. Such communication relies on an open, truthful, honest, and impartial opinion and conduct. Open cooperation within our own company is a basic prerequisite for positive and productive collaboration with our clients and professional partners. A positive working environment and a mutually beneficial relationship between employers and employees fosters motivated and healthy personnel, which in turn contributes to the success of our company.

Therefore, we at gmp treat one another and third parties with respect. We value mutual appreciation and nonjudgmental conduct toward all our colleagues and the people with whom we work. Each of us is obligated to treat colleagues, business partners, and all other people with whom we work with respect, openness, and appreciation. We always treat others in the way that we would like to be treated.

2.2. Human rights and labor law

We observe and support the human rights and labor legislation currently in force. We oppose child and forced labor, human trafficking, and all types of present-day slavery. We recognize freedom of association and the right to collective bargaining. This applies not only to our conduct with regard to gmp, but also with regard to customers, suppliers, and other business partners, and we also expect them to assume this responsibility.

Therefore, all gmp employees are called upon to be alert to human rights violations. If we identify an (imminent) violation of human rights in our business’s sphere of influence, we strive to prevent or stop it.

2.3. Equal opportunity and equal treatment

gmp is international. People of different origins and with different cultural backgrounds work for gmp. Variety and diversity are what we’re all about and are a tremendous asset for the company.

That’s why we at gmp do not tolerate any discrimination. Regardless of whether this discrimination is based on race, ethnicity, gender, religion, worldview, disability, age, or sexual identity. We accept the individuality of each person in the interest of the company.

We also want to influence our business partners in order to contribute to the implementation of humane working conditions.

2.4. Highest quality standards

We are distinctive not only for our creativity, but also for the quality of our planning. We’re conscious of the fact that our activities have a significant impact on people and the environment. As far as possible, we avoid risks and anything that might be detrimental to the health and safety of all those who come into contact with our activities and structures.

Our designs are state of the art. Our work takes into account the latest technology and is in line with legal requirements.

Our quality assurance measures are based on DIN ISO 9000/9001. One fundamental element of our quality management is the seamless documentation of project communication and project progress. Checklists, flowcharts, forms, and other aids are used for project processing. We understand quality assurance to be an overriding concept that safeguards and advances all our activities and actions. Therefore, it goes without saying that we are guided only by the highest professional quality standards.

We set great store by the first-class training of our employees. We require and we support continuing education as well as specialized and personal development as the cornerstones of long-term success. For this reason, regular training courses are the standard at gmp.

2.5. Environmental protection and sustainability

A significant portion of global CO2 emissions is caused by the construction and operation of buildings. As architects and urban planners, we’re particularly aware of our responsibility for protecting our environment.

Our designs aim at customized solutions for future-ready and climate-positive projects that combine building culture with sustainability as a matter of course. We strive to make optimal use of energy and resources throughout the entire lifecycle of all projects. We design, plan, and implement projects on the basis of a holistic approach and are in constant dialog with external planning partners in research, and development. The timelessness and durability of our designs contribute to sustainability to a significant degree. Sustainability is an integral part of our planning.

In our day-to-day office life, we use energy and resources sparingly as a matter of course.

3. gmp as a responsible business partner

As a leading and reputable architectural firm, our reputation is our life. We have built it over decades. Only by working together can we preserve our reputation and our position on the market. Fairness, transparency, and integrity are essential for this.

3.1. Fair competition

We believe in fair competition. Our relationships with customers and business partners are characterized by fairness. We win competitions based on our creativity and the quality of our services. We do not participate in unfair or illegal business practices.

We strictly adhere to the legal regulations regarding the protection of competition. We refrain from exchanging business information if doing so could restrict competition. We independently establish our business strategies and our pricing policy and do not discuss them with competitors. Even if we take part in calls for bids or competitions, we do not coordinate with competitors.

We choose our business partners, and especially our suppliers and service providers, carefully and solely on the basis of objective criteria. We avoid one-sided preferential treatment without an objective basis as well as any conflicts of interest. The same applies when we suggest or recommend specific business partners to our customers during the course of a project. Before we do this or decide to purchase products and services from a business partner, we gather information regarding the market and alternative providers. When we purchase products and services for gmp, we do so according to the applicable procurement regulations.

3.2. Conflicts of interest

We draw a distinction between personal and business matters. We avoid all situations in which our personal interests could influence or could appear to influence a decision that is part of our activities for gmp. We disclose existing or even potential conflicts of interest. We make business decisions based only on objective criteria that benefit gmp.

3.3. Corruption and fraud

We do not tolerate criminal acts. We oppose all forms of corruption and fraud. Criminal acts can cause significant damage to gmp’s reputation and result in sanctions. Employees involved in criminal acts are subject to fines, imprisonment, and claims for damages.

3.3.1. Corruption

Corruption goes against our corporate philosophy and our self-image. It harms societies and economies. It leads to improper decisions, distorted competition, and financial inequality, and it impedes innovation.

Our competitiveness is based on the creativity and quality of our services. We do not need to resort to corruption in order to gain a competitive advantage or obtain a contract. We neither bribe (potential) business partners, officials, or public authorities, nor do we allow ourselves to be influenced by favors or gratuities.

Because of their serious consequences, we are all required to recognize and avoid corruption and bribery. We understand that gmp can also be held responsible for the acts of third parties and that no distinction is made between a bribe or illegal favor offered directly by us or indirectly for us by a third party (e.g. by an intermediary or consultant). For this reason, we carefully select our (potential) business partners.

Unfortunately, it isn’t always easy to recognize corruption and bribery. If we have any doubts about whether a specific situation could involve corruption or bribery, we seek guidance (cf. Section 7 – Help and support).

3.3.2. Fraud

The trust that our customers and business partners place in our integrity and quality is the fundamental prerequisite for long-term success in business. Therefore, we rely on the fact that all information from and about gmp and our projects is true. We neither initiate fraudulent acts nor participate in them. These include:

- False declarations in order to enter into a business relationship or obtain a contract;

- Falsification of documents;

- Manipulation of data, or

- Provision of deliberately misleading information.

We make sure that we do not engage in these or similar behaviors. We also make sure that all the information that we document in our systems is true. If we support customers and business partners with applications (e.g. with public authorities) or supply them with documents for applications, we are particularly careful that the information corresponds to the facts and is correct. We also make sure that we do not participate in covering up fraud or misinformation. If we identify suspicious information or activities, we immediately report them to the Compliance Group.

3.4. Gifts, entertainment, and invitations

Gratuities in the form of gifts, and particularly in the form of invitations and entertainment, are a widespread and customary part of business dealings. They promote the exchange of business and professional information, are a form of courtesy, and are a token of appreciation. But when they exceed reasonable limits and are given with a specific motive, they can also be a form of corruption and bribery.

When we offer customers, business partners, or third parties an invitation or gift, we do so solely in conformity with our in-house regulations and within a socially customary and legally allowable framework. Furthermore, we do not give a gratuity in order to influence a decision. Nor should a gratuity cause its recipient to feel any obligation. We are aware that an especially high standard applies when dealing with office-holders, public authorities, and elected officials (also cf. Section 3.5 – Conduct with office-holders).

Conversely, we accept no gratuities or invitations that are not socially customary or if accepting them would be against the law or our in-house regulations. We also refuse to accept gratuities and invitations if they are intended to influence our decision making or if it would make us feel in any way obligated to the one offering the gratuities or invitations.

In individual cases, it may happen that our in-house guidelines are fundamentally opposed to us accepting a gift, but the act of refusing it – based on local, cultural practices – would amount to an insult. In this exceptional case, accepting the gift is permitted if it is not precluded by legal regulations and the gift-giver is clearly advised that the gift is not accepted personally but on behalf of gmp. We immediately report such cases to the Compliance Group. This Group decides the matter.

3.5. Conduct with office-holders, public authorities, and elected officials

A large part of our activities involve collaborations with public and governmental clients, both at home and abroad. Private-sector projects also bring us into contact with office holders, public authorities, and elected officials.

We are aware that especially strict statutory regulations often apply when dealing with office holders, public authorities, and elected officials. Even a single violation of these regulations can have serious consequences. In addition to damage to our reputation and high financial penalties, gmp also risks being excluded from the award of public contracts.

Therefore, we strictly comply with legal regulations and in-house regulations in our contacts with office holders, public authorities, and elected officials in order to avoid corruption and conflicts of interest. Gratuities, invitations and entertainment are allowed only within very strict limits and should always be avoided. In cases of doubt, we seek guidance (cf. Section 7 – Help and support).

3.6. Donations, sponsorships, and charity

gmp promotes charitable and not-for-profit causes. gmp also commends employees for personally donating to or volunteering for such causes.

gmp allows monetary and in-kind donations for culture, training, and charitable causes, among other things. The fundamental prerequisite for a donation is that the particular institution receiving the donation be recognized as non-profit or be authorized to receive donations due to special regulations.

We do not donate to political parties, party-affiliated institutions, or politicians. This applies equally to monetary and in-kind donations. Nor do we sponsor any events, etc., held by political parties, party-affiliated institutions, or politicians.

We understand a donation to be a voluntary service to a third party without the reception or expectation of a service in return. In addition to monetary and in-kind donations, this also includes voluntary work as part of “pro bono” projects.

In the case of sponsorship, gmp receives a promotional consideration, such as the presentation of our logo or planning designs in the context of a sponsored event or the mention of gmp as a sponsor.

For us, sponsorship comes into question only if it is favorable to the development of gmp and is transparent. If, for example, we present designs within the context of sponsoring an exhibition, we do so only if it is clear that we are a sponsor of the exhibition. Conversely, we make our sponsors transparent if, for example, we ourselves organize an exhibition. As sponsor and organizer, we accept only such sponsorship as is on a contractual basis, is for a suitable cause, and for which the relationship between service and consideration is customary and appropriate.

We comply with legal regulations regarding donations and sponsorship activities. The decision regarding a donation or sponsorship is made exclusively by the managing partners.

3.7. Money laundering and financing of terrorism

gmp supports the international fight against money laundering and the financing of terrorism. We follow legal regulations in this regard. We neither take active part in money laundering transactions nor do we support or tolerate them.

Money laundering includes channeling money from criminal activities into the economic cycle in order to disguise its criminal origin. It makes no difference whether the criminal acts from which the money originated were committed at home or abroad.

To ensure that we ourselves do not become involved in money laundering, we must be vigilant. We enter into business relationships only with reputable partners. For this reason, we verify the identity of customers, business partners, and other third parties before we enter into a business relationship with them.

We make cash receipts and cash payments transparent and traceable by immediately recording all business transactions. If we notice any suspicious circumstances, we immediately notify the managing partners.

3.8. Embargos, economic sanctions, and trade controls

gmp is internationally active and involved in projects in various countries around the world. Wherever we are active, we must observe the applicable import, export, and trade laws.

This particularly applies to embargos and economic sanctions, meaning the ban on providing certain services relating to the countries affected by them. The same applies to business transactions with people and companies on the sanctions list.

Therefore, before we conclude a contract with customers or other business partners, we verify whether embargos, economic sanctions, or trade controls can conflict with entering into a business relationship. If we are unsure, we seek guidance (cf. Section 7 – Help and support).

4. gmp at the workplace

Our conduct at the workplace is also a significant factor in gmp’s long-term success. It also contributes to a safe and healthy work environment.

4.1. Occupational health and safety

We ensure that all our colleagues in our offices can work under safe and healthy conditions in accordance with our in-house regulations and the applicable national laws. We provide our employees with appropriate equipment and procedures and offer them the necessary information and training courses.

We consider it self-evident that when we are working on construction sites, we comply with the rules that apply on these sites and wear the prescribed personal protective equipment (PPE). We comply with legal regulations and guidelines relating to behavior on construction sites.

We also expect that our business partners will comply with the applicable laws and guidelines regarding safety on construction sites and that they will also support the safety and health of those people who are affected by their activities.

If we become aware of violations of occupational safety rules on a construction site, we immediately report them to the site manager and to the responsible supervisor.

4.2. Treatment of company property and assets

We use company property and assets belonging to gmp carefully and sparingly. We protect them against damage and misuse. We purchase tools and other equipment with gmp’s best interest in mind and always act thriftily.

We make a strict separation between personal and business uses. The occasion, scope, and timing of entertainment and business trips must always be job-related and comply with the regulations of in-house guidelines. In cases where it is difficult to precisely distinguish between business and personal, a supervisor must be consulted.

4.3. Information security, trade secrets, and intellectual property

We are hired for our sketches, drawings, designs, and plans. They are products of our creativity – unique, individual, and innovative. As our intellectual property, they are what gives us an edge in competition. Our information and our knowledge are of supreme importance to our business activities. To a substantial degree, our reputation is built on integrity and confidentiality. Only if our intellectual property and our trade secrets are protected do we also remain successful over the long term.

We are extremely careful to protect our intellectual property and our trade secrets, such as the information that we save on our projects, plans, customers and partners. We do not share information relating to gmp, such as designs and plans, with third parties without authorization. The same applies to our knowledge and information about projects, in-house processes, customers, and partners. We do not share this information with external persons, companies, or organizations without authorization. We protect our trade secrets and our intellectual property against infringements – including legally, using all the means at our disposal.

We also respect the intellectual property, especially copyright, and the trade secrets of our competitors, business partners, and other third parties. We treat the information that becomes known to us confidentially.

4.4. Data privacy

The protection of personal data is important to us. Personal data is all the information relating to an identified or identifiable natural person, where it is immaterial whether they can be identified directly or indirectly, e.g. by consulting other data.

The collection, storage, use, and any other type of processing of this data always requires the consent of the relevant person, a contractual arrangement, or legal permission. Therefore, we handle personal data confidentially and process it only within the context of legal regulations. Above all, we keep the amount of data as low as possible. That means that we only collect, store, use, and process as much data as is necessary for our activities. We do not exceed the limits of the consent or other authorization. As employees of gmp, we are prohibited from processing personal data without authorization. If there are doubts about the permissibility of processing data, we seek advice from our data protection officer. If we learn about a data privacy violation by gmp itself or by customers or business partners, we immediately report it to the data protection officer.

4.5. IT security and the use of electronic resources

Our work is highly digitized, meaning that it is supported by information technology (IT) and electronic data processing (EDP). At the same time, hacker attacks against IT and EDP equipment in the form of computer viruses and malware are increasing exponentially. In addition to the risk of damage to our IT infrastructure and data loss, there is also a risk of reputational damage and high material damage.

For these reasons, we do our best to protect our corporate network and our IT and EDP equipment. We are careful when we receive e-mails or data transfers. Above all, we never open e-mails or their attachments if they appear suspicious or if the sender is unknown to us. If customers or business partners send us unsolicited data, we carefully check whether it really came from the specified sender.

We use the IT and EDP resources provided by gmp according to our current IT usage policy. Personal use of a work e-mail address is prohibited.

If we need specific software, we first have it authorized and installed by the IT department. We do not load or copy any information relating to gmp, customers, or other business partners to online services without authorization.

We immediately report security-related incidents and abnormalities to the IT department.

4.6. Marketing and communication (especially public statements by employees)

Clear and open communication is important to us. This applies to ourselves as well as to our customers, business partners, and the public. At the same time, we make sure that we do not disclose or share confidential information.

Statements for and in the name of gmp to the public and the media, on social networks, etc., are issued only by prior arrangement with the extended management team or the PR department. If we receive a media inquiry or are asked to make a statement, we forward the request to these parties.

The use of social networks and media has numerous positive effects but can also have negative consequences. Therefore, we support their active use in an informed manner.

When using social networks, we always comply with the following basic rules:

- We are always polite. Insults or harassment of other people or companies are against our character.

- We do not disclose any confidential or in-house information.

- We do not personally answer questions about gmp but instead forward them to the extended management team or the PR department.

If, in the context of using a social network, gmp is recognizable as our employer, we consider the company’s reputation when expressing our views. We never take part in public discussions about gmp, projects, customers, or business partners. Other users might perceive our posts as official statements. If we find such a discussion, we inform the extended management team or the PR department so that they can respond appropriately.

Our acquisition and PR activities are based on appropriate planning. Therefore, we coordinate all such activities with the Business Development and Public Relations departments before we implement them or make corresponding commitments.

4.7. Taxes, customs, and financial accounting

We comply with national and international tax and customs regulations.

In the context of our international business activities in particular, many different tax and customs laws are relevant. If we have any questions, we consult the Accounting/Controlling departments.

We also adhere to the statutory framework conditions for proper accounting. Revenue and expenditure musts always be posted correctly, transparently, and traceably. We verify whether invoices are correct.

If we obtain evidence of a violation of tax and customs regulations, we immediately contact the Accounting/Controlling departments to avoid damage.

5. Handling of violations

Regardless of our position, we all align our behavior with this Code of Conduct. Violations can have far-reaching consequences for gmp, for our colleagues, customers, and business partners, and for ourselves.

When we talk about violations of the Code of Conduct, what matters most is that we treat each other constructively, in line with our open corporate and error culture. It is the only way that we can continue to develop.

At the same time, it is clear that gmp must and will respond appropriately and consistently to objectionable, conscious, and/or repeated violations of the Code of Conduct within the framework of the legal provisions.

6. Whistleblower System

We value open communication.

In line with an open corporate and error culture, we are always interested in learning so that we can continue to develop.

This also applies when, in your reasoned view, something appears to be wrong and might be a violation of the Code of Conduct, in-house guidelines, or legal regulations. We take every concern seriously and will carefully verify these violations. This is the only way that we as a group can improve our behavior and protect gmp.

Our People and Culture Manager³ is available to you as a central contact. On the Intranet, you will also find a system for submitting anonymous tips⁴.

This system is available to us for anonymously reporting a (possible) rule violation if – for whatever reason – we do not want to consult our supervisor or the People and Culture Manager directly.

Regardless of whether a tip is anonymous or the person’s own identity is disclosed, gmp follows up on every tip. For us, extreme confidentiality in the handling of tips is a given.

Colleagues who report a violation or a related suspicion in good faith can count on the support of the managing partners and gmp at all times.

7. Help and support

If we are unclear about something or if we need help or support for properly applying the Code of Conduct to our work lives, we seek advice from in-house departments as well as from external experts.

The Compliance Group¹ is available as a central contact. We can also talk to our supervisors at any time.

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¹ See the gmp Intranet under Administration/Compliance
² Cf. Section 7 – Help and support
³ See gmp Intranet under Administration/Communication/Contacts
⁴ See gmp Intranet under Administration/Compliance

December 2023