blackned GmbH

Company Policy

Preamble

blackned has declared to this voluntary committed policy on protection of personal data, fair market behaviour, its consciousness on sustainable business and environmental protection. This policy is in place to serve as a guideline for any prosper and success-oriented company and blackned intends to make sure that this policy is applicable all along our supply chain. For this reason, this policy shall be seen as a standard for both, blackned and its partners.

To ensure this policy and its content will be taken seriously blackned expects any business relationship to be mandatorily based on this – or a similar own – policy and its preconditions, applying to any partner`s and partner`s supply chain.

blackned reserves its right to inspect whether or not its partners and / or suppliers comply with the standards of this policy and to provide evidence of compliancy in case of reasonable doubts. Such evidence can be provided e.g. by conducting an audit at partner`s site, if a less severe mean is not applicable for a reasonable effort.

Compliancy to this policy shall be deemed to be an essential obligation to any contractual relationship between blackned and its partners and suppliers.

For this, blackned indicates strongly that a consent to this policy is an indispensable precondition for any current and / or future relationship, whereas consenting to another policy might be sufficient as long as such policy does not stand back to the requirements of this blackned`s policy.

For this reason – and as blackned is confident that any current partner and / or supplier is easily able to comply with this policy – blackned is asking you for your commitment to this policy by signing this document for yourself or on behalf of your company. This policy and its preconditions shall be an integral part of any business relationship between blackned and its partners.

Company Policies

1. Personal Data Protection

blackned is obligated and willing to protect any personal data and we do expect at least the same level by any of our partners. Protection of personal data intends to protect the data itself as well as any related rights of a person. For this, next to possibly applicable national regulations, especially the European General Data Protection Regulation (GDPR) applies and is mandatorily to be respected. You can find further information e.g. by following ehttps://www.bmwi.de/Redaktion/DE/Artikel/Digitale-Welt/europaeische-datenschutzgrundverordnung.html.

2. Non-Disclosing Obligation and Business Secrets

To ensure protection of business secrets and any party`s interests, there shall be in place a mutual non-disclosing-agreement of blackned and its partner. In case there might not or not yet be such agreement, blackned expects any partner to protect any information that might likely be suitable to cause damages for blackned, other partners or another relevant third party. This goal can be reached for instance – among other standards – by disclosing such information only to such employees and or third parties who has a need-to-know about such information to be able to serve contractual obligations

3. Protection of Classified Information

Classified information is governmental sensitive information that must be specifically protected and publicly access to it is strictly restricted. Access to and handling of such information is regulated strictly by the relevant public body. To gain access a formal security clearance is usually required. However, it might occur that such sensitive information might happen to be disclosed (with or without intention). In such case neither blackned nor any of its partners is allowed to further disclose this information but is obligated to consult blackned without undue delay and prevent any further disclosing.

4. Intellectual Property Rights and Copy Rights

Respecting intellectual property rights and copy rights of any third party is mandatory for both, blackned and its partners. This does include any kind of right, e.g. intellectual and industrial property rights, patents, trade and business secrets and similar rights of any kind.

Any partner is especially obligated to check and verify that used third-party software is either free of restrictions of use or its use comply to such restrictions.

5. Fair Employment Practices

Protection of and respect to any employee of both sides has a high priority to blackned. For this, blackned expects any partner to comply with a minimum standard of social responsibility and no less than by the applicable law is required all along it supply chain.

6. Prohibition of child labor and forced labor

Next to any applicable national law and its minimum standards on child labor and forced labor, the preconditions of the ILO-Convention 138 does apply, whereas any regulation with a broader level of protection shall always prevail.

Any Partner is obligated to ensure all along its supply chain that minimum standards are complied with. Free choice of kind and place to work at for any employee must be granted and any kind of forced labor must be avoided.

7. Discrimination

Any partner is obligated to prevent any kind of discrimination of a person for its race, (ethnical) origin, skin color, sex, sexual orientation, religion or any kind of religious belief, disability or any other characteristic that might be able to lead to any kind of discrimination.

In this context, discrimination shall mean any kind of unequal treatment (under comparable preconditions), including bullying, harassment, or any other inappropriate snide or derogatory remarks based on one of the above characteristics.

8. Human Rights and Conflict Minerals (3TG)

Without any limitation blackned acknowledges to any person its human rights. This does also and especially apply to the sourcing of any Conflict Minerals (3TG) and it use and processing during any process. Blackned acknowledges that it will only process such conflict minerals which are certified to be conflict-free or which`s sourcing and supply chain has been at least conducted a positive due diligence audit.

For more information please visit e.g. https://www.umweltbundesamt.de/sites/default/files/medien/378/dokumente/umsoress_kurzsteckbrief_cfsp_final.pdf

9. Environmental Protection

National and international standards to protect the environment, natural resources and to prevent pollution within any process must be complied with. As far as possible pollution and wasteful use of energy, natural resources and any other kind of recourses shall be prevented. Any partner and supplier shall have an Environmental Management System (EMS) that regularly includes audits to detect and conduct improvements by a continuous improvement process (CIP). If mandatory and applicable, any partner is obligated on its own behalf to get environmental public permissions, if so.

Blackned`s EMS is certified as of ISO 14001:2015. We do expect from any partner to be able to provide evidence on request that its own standards do follow this or similar standard, too.

10. Corruption

Next to any action with a risk of penalties according to the applicable law(s), any direct or indirect corruptive behavior shall deem to be intolerable behavior and be understood to be against any principles of fair business. Any partner and supplier is tasked to set reasonable controls in place to avoid any such behavior, regardless if this behavior is conducted by one of its managers or other employees or by a third party on behalf. This applies also whenever there might be only a suspicion about corrupt behavior. 

In case partner will detect any corrupt behavior, partner is obligated to inform blackned and any interested party and further, do to anything reasonably required to end such behavior and reduce potentially damages to its minimum.

11. Conflict of Interests and Bribery 

Criteria for choosing any products, services, suppliers, employees, subcontractors or other relevant performances by partners and suppliers must only be chosen upon objective criteria like quality, offered prices, known reliability and similar. Personal or financial interests which might cause blackned or another interested third-party on blackned`s side any kind of damage must not be considered as a relevant criterion and must be excluded as a relevant standard. This especially applies for cases when a person appears to have interests for more than one party, both, by a contractual or non-contractual relationship.

In case such conflict of interests will appear, partner and / or supplier is obligated to inform blackned on that circumstance without undue delay to prevent unnecessary damages.

12. Market Conduct Rules – Fair Business

Anticompetitive agreements about prices, offers – with or against a competitor – suppliers, products, processes or any other such agreement which are likely to violate against a competition and / or antitrust law or any such attempt are strictly forbitten.

13. Export Control and Customs

Compliance to any applicable import and export control, embargos and any regulation on customs and customs clearance is a mandatory precondition to ensure a durable protection of blackned`s business interests and a contribution to global safety. For this, any partner and supplier must strictly comply to these obligations on their own behalf with any such applicable regulation and to conduct controls and a due diligence all along its whole supply chain and products and own partners.

Compliance to this policy is a mandatory precondition for any business relationship of blackned with any third party.

In case a partner might struggle to comply with any of the mentioned regulations above we are kindly advising you to contact blackned by any preferred way to identify such issue and find a way to be compliant.