Our Code of Conduct
In a rapidly changing and highly competitive world, it is vital to stay focused on what really matters to us at BASF. Our values – creative, open, responsible, and entrepreneurial – help us do this. They remind us of what BASF stands for and serve as a yardstick for how we do business.
We are strictly committed to high standards of legal compliance and business ethics. Our Code of Conduct defines the boundaries within which we as BASF employees must act to comply with laws and internal policies. By doing so, it protects BASF and each of us.
Our Code of Conduct guides us to put our values and commitments into practice – throughout the company, and in everything we do. It helps us navigate through areas and situations where responsible conduct and ethical decision-making are critically important. Only when we fully comply with our Code of Conduct, and all laws and regulations, we can achieve our aspiration to be the world’s leading chemical company, respected and trusted by our customers, investors, employees and all other stakeholders.
Our Code of Conduct cannot cover in detail the wide variety of situations we may encounter. Each of us is responsible for ensuring we understand BASF’s policies and procedures, and for maintaining the high ethical standards in every aspect of our work – even when our Code of Conduct provides no direct guidance. We are always expected to show both integrity and common sense. When in doubt, we always speak up and ask for help.
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Anti-corruption, trade control and anti-money laundering
We do business with integrity. Always, without exception.
At BASF our reputation for doing business with complete integrity is critical. We are committed to fighting any kind of corruption or bribery. We play to win, but strictly within the rules, treating all business partners fairly and competing for business based on the quality of our products and services. Naturally, we expect the same from those we do business with.
We do not get involved in corruption – whatever form it takes. We do not offer or accept bribes and we do everything we can to prevent bribery by others who act on our behalf, for example, by appropriately checking third parties with whom we do business or who provide services.
Furthermore, “facilitation” or “grease” payments (i.e., small cash or non-cash benefits to office holders to facilitate administrative procedures or official acts, e.g., customs clearances, to which the company or the individual is entitled) are not allowed. If, however, the refusal to make facilitation payments would put your personal safety at risk, you may make such a payment but must inform your manager thereafter.
Always vigilant against corruption
Corruption can take many forms, so we are always vigilant and on the alert for any suspicious behavior, such as a business partner asking for unusually high commissions or payments in cash or refusing to accept anti-corruption contract requirements or our Supplier Code of Conduct.
We would rather lose a business opportunity than win by means of corruption. Bribery – whether of a governmental official or in the private sector – is always wrong and has no place in our business.
Political activity and lobbying
We conduct our lobbying and political communications in accordance with transparent guidelines, our publicly stated positions and all applicable laws. As a company, we engage in political lobbying to advance our company’s interests, but we do this transparently and do not financially support political parties or organizations close to them.
We do business across borders. But always within legal boundaries.
We are a global company with activities and business partners all over the world. We are aware that all business relationships with domestic and international partners may be subject to trade control laws. Overall, our goal is to prevent our products from falling into the wrong hands, where there is a risk of them being misused. So, we strictly adhere to all applicable laws, including trade control regulations like embargoes, anti-terrorism laws and further regulations aimed at preventing misuse.
We do business globally which means our activities are subject to various national and international trade laws, restricting or prohibiting the import and export of our products or services. These restrictions can be based not only on the nature of the product, but sometimes also on the country of origin or destination, or even on the identity of the customer.
Export controls can take many forms. Besides restrictions on physical goods, software and services may also be controlled. Export controls can even apply to technology transfer, for instance the exchange of information relevant to the trade control law shared via electronic means like email or an online collaboration site or transported across borders on electronic devices.
Trade control regulations are a sensitive topic, but our Global Trade Control Team helps us navigate within these boundaries, because employees need to be familiar with, and sensitive to, the issues of export/import controls. Take advantage of their expert knowledge if you have any questions relating to trade control regulations.
We are always on guard against dirty money.
At BASF, we do not allow dirty money to play any part in our business. But while it is easy to state that as a fundamental principle, protecting our company against attempts by criminals to "clean" cash and other assets generated by illegal activities is a challenge that demands constant vigilance, from us all. Because being involved in money-laundering or terrorism financing – even inadvertently – is a criminal offence.
We are always keen to do business, but only with reputable partners who operate within the law, using resources from legitimate sources. We carefully check the identity and credentials of potential customers, business partners and other third parties. And we take all reasonable measures to ensure transparent business relationships.
Money laundering is a deliberate attempt to move cash or assets derived from criminal activities into legal and legitimate financial activities. At BASF, we take all reasonable measures to prevent our company being used as a means to launder money.
To protect our reputation and avoid any possible criminal liability, we need to be constantly vigilant about the activities of business partners, so we know who we are dealing with before contracts are signed, or transactions occur, and watch out for payment irregularities or suspicious behavior, on the part of customers or others.
Antitrust law, gifts and entertainment, conflict of interests
We compete to win. But always fairly.
At BASF, our aspiration is to be the world’s leading chemical company. To achieve this, we always act fairly as we know there are no short-cuts. For us, the only kind of success worth having depends on winning, and maintaining, the long-term trust of our customers and business partners.
We are committed to conducting our business solely on the basis of free and fair competition, and we strictly obey all applicable laws and regulations. We believe that fair, well-regulated competition strengthens our market and benefits our customers.
As a market leader in various fields, BASF has special obligations under antitrust law for conducting our business in a way that promotes fair competition. We welcome this extra responsibility, and aim to lead by example, to achieve the best for our customers.
We are aware that any violation of antitrust laws can result in heavy fines, and even imprisonment, for the company, management and individuals concerned. In the EU, for example, fines for antitrust violations could amount to up to 10% of BASF's total global sales. It is up to all of us to be alert for any situation that could potentially be seen as harmful to free and fair competition.
For agreements between competitors (companies on the same level of the supply chain – also called horizontal agreements), the strict regulations of European antitrust law must be complied with worldwide, irrespective of local laws that may be less strict or non-existent. This also applies to “concerted practices” between competitors, which may be triggered even by a one-sided sharing or receiving of information.
We build great relationships. But not through gifts.
We are all in favor of doing business in a way that builds great relationships. But gifts and entertainment need to be regarded with real caution. And when there is any doubt, we ask questions, we talk to each other, we act with caution and make our actions transparent.
Gifts and entertainment
We do not consider it appropriate to accept or grant a personal benefit of any kind in connection with our professional activities. But in the course of good business relationships, a small gift or modest invitation may sometimes be offered based on what is considered reasonable and customary. In such situations, we need to exercise caution and common sense, to avoid any possible misinterpretation of motives and reputational damage. Invitations may be okay with regard to our internal rules but may have a bad taste due to the situation and other circumstances.
We think carefully and only offer or accept gifts which have a moderate value and are understood to be simply business courtesies, and not an attempt to induce us to act unprofessionally, or to misuse our position. We also pay attention to the image that can be created due to the external circumstances and the overall situation. We use the same standard when deciding whether to offer or accept a gift. We do not offer or accept cash or cash equivalents such as gift cards or shopping vouchers.
We are particularly cautious when dealing with public officials or government representatives because we adhere to the often very strict rules that govern this in many countries.
We take care of business. Not our own personal interests.
It may sound obvious that when we are at work, all our actions and decisions should be based on what's best for the business. But conflicts of interest - situations where personal gain may influence our professional judgment - can and do arise. It is vitally important that we know how to recognize potential conflicts of this kind, and that we disclose them before any damage is done to the trust our company's success is built upon.
Conflicts of interest
We are well aware that our personal relationships and interests should never affect our business activities or influence our decision-making, in any way. We need to be careful to avoid situations where a conflict between private and professional may arise – or, just as important, where it may appear to do so.
This means, for example, that we should not make any investment, or enter into any relationship, that may cause others to doubt our fairness, integrity or ability to perform our duties fairly objectively.
It is important to make the point that having a conflict of interest is not, in itself, misconduct – but the way we handle it could be. It is all about transparency; if we suspect a possible conflict, we need to raise it with our manager, without delay.
Human rights, labor and social standards
Environmental protection, health and safety
We treat people fairly and with respect.
We treat people with fairness, consideration and respect. Our aim is to ensure that each individual feels valued, and fully supported in achieving their personal best. Always, and without exception.
Human rights, labor and social standards
We value people and respect human rights. As a company aiming for profitable growth, we have made the decision to pursue sustainable value creation, which means striving to positively contribute to the protection and promotion of human rights and people's well-being.
We commit to internationally agreed-upon standards, such as the United Nations’ Universal Declaration on Human Rights, the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises and the Tripartite Declaration of Principles Concerning Multinational Enterprises and Social Policy (MNE Declaration) of the International Labor Organization (ILO).
In our own business activities, we avoid causing or contributing to adverse human rights impacts. As a participant in numerous global value chains, we are dependent on partners and demand that they likewise respect human rights and the associated international labor and social standards (ILSS). We offer to help our partners in their efforts to meet their human rights responsibilities.
Respect in the workplace
Everyone at BASF should always feel valued and respected. So, we expect every one of us avoid saying or doing anything that is humiliating, condescending, offensive or otherwise disrespectful to our colleagues. This is fundamental for our motivation and dedication at work.
We built our team on talent and appreciate the differences in our team because they make us stronger and are essential to our success. We promote an inclusive environment that embraces diversity of all kinds, including a wide variety of backgrounds, thoughts, perspectives, demographics, ethnicities, and origin.
We do not tolerate discrimination or harassment against anyone based on grounds such as age, race, color, sex, sexual orientation, gender identity/expression, national origin, religion, disability, genetic information, or any other personality traits or preferences. This governs all our employment decisions such as recruiting, hiring, promotions, benefits, disciplinary actions or terminations.
We value the health and safety of people above all else.
Wherever we do business, we act responsibly – not just complying with all relevant regulations but going the extra mile to reduce risks and minimize our environmental impact.
Environmental protection, health and safety
We are committed to energy efficiency and climate protection, and are constantly working to develop sustainable solutions for our business operations and for our customers. Across all our operations and in close collaboration with our suppliers, we work to achieve the highest standards of health and safety, and to maintain the trust of our employees, customers, business partners and other stakeholders. In the event of any kind of incident or emergency, we are well prepared to take whatever action is necessary.
We support, among others, the UN Sustainable Development Goals Climate Action (SDG 13), Responsible Consumption and Production (SDG 12) and Zero Hunger (SDG 2). And to this end, we work continuously to reduce the greenhouse gas emissions from our business activities and reduce emissions to water from our production processes.
We aim to use products and resources in the best way possible across the entire value chain and act responsibly when we operate our plants and when our goods are transported around the world.
A business that demands we take extra care
In terms of environmental protection, health and safety, we are aware that the nature of our business demands that we take exceptionally good care to reduce risks and prevent accidents. The protection of people and the environment is our top priority. Our core business – the development, production, processing and transportation of chemicals – demands a responsible approach. We systematically address risks with a comprehensive Responsible Care Management System. We expect our employees and contractors to know the risks of working with our products, substances and plants and handle these responsibly.
We review the safety of our products from research and development through production and all the way to our customers’ application. We continuously work to ensure that our products pose no risk to people or the environment when they are used responsibly and in the intended manner.
A commitment shared with our partners and suppliers
We do not just set ourselves ambitious goals for safety and security, health and environmental protection; we expect our business partners to aim equally high. In particular, we count on our suppliers to be fully engaged with these goals, and work with them to improve their sustainability performance.
Sensitive company information, personal data, digital responsibility, accurate books and records
We protect the information our success is built upon.
Sharing information within BASF and with our partners enables us to create value for the company and our customers, and to benefit from the wealth of knowledge of our employees. To protect our know-how, we take every reasonable measure to prevent unauthorized disclosure or misuse, across all our business activities and every form of communication.
Information Protection and Cyber Security
We build on our intellectual property because confidential information and intellectual property of many kinds – from individual expertise to internationally protected patents – are some of our most valuable assets. So, we take the greatest care to protect them and equally, of course, we respect the intellectual property of others.
We comply with all applicable policies, requirements and guidelines on Information Protection and Cyber Security, and regulate consequently the sharing of confidential information. We do not share confidential information on social media or in public places.
Using price sensitive non-public information when trading shares could be gravely damaging to the integrity of the markets.
When we have access to inside information, we do not use it to trade in, or recommend trading in, financial instruments and we never disclose such information. Trading in shares or other financial instruments while being in possession of relevant inside information is strictly prohibited. We always handle sensitive company information responsibly.
In our working lives at BASF, we may well have access to non-public information about BASF, or the affairs of a third party, which could have an impact on the value or price of publicly traded securities, in particular BASF shares. Insider trading laws prohibit making use of such inside information in securities trading or disclosing it to third parties, including friends or family. And anyone violating these laws may face severe criminal penalties and financial liability.
We take care to protect personal data.
In our everyday business activities, we collect and handle a lot of personal data relating to individuals, such as employees, customers and business partners. We never forget this data is private and must be treated with respect – not just because laws strictly demand it, but also because it is the right thing for a responsible business to do.
We are committed to respect the personal rights of everyone. We adhere to strict standards when we handle personal data. All personal data collected by us will be processed fairly, transparently, carefully and in full compliance with the applicable legal requirements. It is part of doing business with integrity to always treat personal data confidentially. We protect personal data from unauthorized access or loss.
We leverage digitalization across the company.
It is no exaggeration to say that digital technology is changing almost every aspect of our lives. And, of course, for companies like ours, that poses some challenges, as traditional business models and norms are disrupted. But we are excited by the amazing opportunities offered by digitalization to create additional value for our customers, improve the efficiency of our processes, and strengthen our capacity for innovation.
We are an innovation-driven company and create chemistry for a sustainable future. To ensure our long-term success and support the success of our customers, we make use of the chances of digitalization. We thoughtfully and efficiently integrate its benefits into the way we do business and leverage its potentials for our business conduct as well as for our products and customer solutions.
A transformation driven by our values
Digitalization is crucial to staying competitive and is therefore one of our strategic action areas. To stay ahead of the competition, we need to accelerate the execution of digital projects and build strong digital capabilities throughout the company. Technologies like augmented reality, machine learning, cloud computing, AI, or others are often used to create exciting customer experiences, new digital business models or make processes more efficient.
We also recognize the significant impact of digitalization on our employees, our customers, and wider society and are committed to steering this transformation responsibly and ethically, for the benefit of all stakeholders, by:
- ensuring that developments and usage are driven by our values and the principles laid down in our Code of Conduct, our guidelines and policies.
- developing digital solutions in a collaborative, multidisciplinary, and diverse way – and using them inclusively, to empower our employees, customers and other stakeholders.
- seeking to avoid or reinforce unfair bias.
- communicating openly information on technical abilities and intended usage of digital solutions and providing means for oversight and control by customers and other users.
- safeguarding data protection and privacy as core principles in all digital solutions, as reflected in our Code of Conduct.
- upholding quality and safety standards, as we do with all our products.
- acknowledging that many challenges will require broader discussions across industries, disciplines and borders, and being an active voice in this debate.
We take care to handle company assets responsibly.
From stationery and office furniture to computers and cars, there are many kinds of company property that enable us all to do our jobs to the best of our ability. Naturally, we treat all such assets responsibly, protecting them against loss, damage, theft or misuse. And of course, exactly the same applies when we handle property belonging to any of our customers, business partners or other third parties.
We regard it as fundamental to our values that all of us in BASF should handle company property with due care and respect. And not just physical assets; it is equally important to be responsible in the way we deal with intangible assets, such as intellectual property rights, copyrighted material, financial records, and also our brand reputation.
We build trust with reliability and transparency.
For our company to be regarded as trustworthy by all our stakeholders, the accuracy and integrity of our books and financial and nonfinancial records must be beyond question. In addition, of course, any irregularities in accounting or reporting can have serious consequences, for the company and the individuals responsible. Our internal control systems are essential to ensure that the numbers and records always comply with the relevant legal requirements.
Accurate books and records
We are convinced that keeping accurate records which give a fair, transparent and complete picture of our business is a critically important responsibility that lies in all our hands. We expect the same standards of honesty and integrity to apply across all business records, from research results to expense claims.
We strictly comply with all statutory requirements for proper accounting and financial reporting as well as tax laws and regulations. We further place the highest importance on creating records that reflect the true nature of the transactions and activities they document.