Compliance

I. Safeguarding human dignity

Respecting and protecting the dignity of every individual and their personal rights is a fundamental value of all actions of MOIN Film Fund, Filmfest and CED (cf. Art 1 GG)

II Equal opportunities and anti-discrimination

MOIN Film Fund, Filmfest and CED are committed to equal opportunities in the selection of their employees and do not discriminate against anyone on the basis of ethnic origin, nationality, religion, age, skin colour, gender, sexual identity, pregnancy, health, disability or other characteristics. They also do not tolerate any discrimination by their bodies, employees, business partners or other third parties. See Anti-discrimination law and Hamburg Equal Opportunities Act.

They are committed to diversity in the film industry. The MOIN Film Fund has Diversity checklists which must be observed as part of the application process.

The Equal Opportunities Officer of MOIN Film Fund can be contacted at the email address gleichstellung@moin-filmfoerderung.de .

III Tolerance, appreciation and respect

Tolerance, appreciation and mutual respect are the basis for collegial and constructive cooperation and interaction. MOIN Film Fund, Filmfest and CED are committed to respecting the personal dignity of others and to treating colleagues, employees and business partners in an objective, friendly and fair manner. Abuse of power and sexualised violence are not accepted.

IV. Neutrality

MOIN Film Fund, Filmfest and CED are committed to party-political neutrality. This applies accordingly to their employees, who exercise the necessary moderation and restraint in the political sphere in the performance of their activities for the respective companies.

V. Integrity

Members of the bodies and employees as well as volunteers and members of the funding bodies make their decisions objectively and independently of any extraneous considerations. If personal and/or economic interests are involved in the decisions, these must be disclosed. In the event of conflicts of interest, the decisions must be transferred to other, independent functionaries or the decisions must not be participated in. See section 5.6 of the Hamburg Corporate Governance Code.

VI Compliance with laws and guidelines

Compliance with the applicable laws and regulations, the internal rules and guidelines and the contractual agreements concluded and self-imposed voluntary obligations is a matter of course for MOIN Film Fund, Filmfest and CED. They oblige their bodies and employees to familiarise themselves with and comply with the internal rules and guidelines, including those made available via the internal network. Applicants and funding recipients are obliged to comply with the Guidelines for film and media funding committed.

VII Behaviour in business transactions

The reputation and public image of MOIN Film Fund, Filmfest and CED are significantly influenced by the behaviour of the members of the bodies, employees and volunteers as well as the members of the film funding bodies. The trusting and respectful relationship with business partners of MOIN Film Fund, Filmfest and CED must be ensured through a legally correct relationship with and legally correct dealings with business partners. This also applies to any consultancy agreements with former board members and executives.

VIII Transparency and data protection

MOIN Film Fund, Filmfest and CED stand for the greatest possible transparency in relevant decision-making processes while at the same time complying with the requirements of confidentiality and data protection.

Funding decisions are published and remain in the Project archive viewable.
The personal data of MOIN Film Fund, Filmfest and CED employees and their business partners are treated in compliance with the applicable laws on collection, storage, processing and transfer. The following apply Hamburg Transparency Act and the GDPR and the BDSG.

The companies MOIN Film Fund, Filmfest and CED have each appointed their own data protection officers. The contacts of the responsible persons can be found in the appendix to this Code of Conduct.

IX. Business secrets

All business activities must be carried out responsibly and records must be kept correctly. All business transactions must be documented properly and transparently. The storage of documents must be ensured. The disclosure of confidential information and business secrets is strictly prohibited. Confidential information may be in digital, verbal or written form. The unauthorised disclosure of confidential information may have consequences under criminal and civil law. MOIN Film Fund, Filmfest and CED employees are obliged to take special care to protect confidential information, especially if this information is on portable, private or third-party-owned media, in order to minimise the risk of theft or misuse. The employees of MOIN Film Fund, Filmfest and CED will not use information provided by third parties if there is a suspicion that the third party has obtained this information due to a breach of a confidentiality agreement. This does not apply if information is generally known to the public or if the employees have obtained it independently of the third party's communication.

X. IT compliance

In addition to data and confidentiality protection, MOIN Film Fund, Filmfest and CED are also committed to IT security, as described above in sections VII and VIII, and have commissioned an external specialist to monitor IT security.

The Framework security concept of the Free and Hanseatic City of Hamburg.

XI. Tax compliance

MOIN Film Fund, Filmfest and CED are committed to the legally compliant tax treatment of all business transactions. All business transactions must always be carried out properly and documented transparently. Transactions with related parties or their companies must be disclosed. All transactions must be capable of third-party comparison, i.e. they must be concluded on terms that would be granted to any third party. There must be no funds or assets that are not recorded in the accounts. An external tax consultant assists MOIN Film Fund, Filmfest and CED with the bookkeeping and preparation of the annual financial statements.

XII. Sustainability and environmental protection

Environmental and health protection are fundamental values in the actions of MOIN Film Fund, Filmfest and CED, which are committed to future-oriented sustainability. Resources are used sparingly. The contact details of the sustainability officers can be found in the appendix to this Code of Conduct.

MOIN Film Fund has created a green mission statement for applicants and employees and developed mandatory criteria catalogues for the production and distribution of audiovisual projects in order to promote sustainability.

Guides on the fields of Green Storytelling, Green Cinema Measures, Ecological Distribution, Ecological Office and Ecological Set have been created and are available.

XIII Working conditions and safety in the workplace

It goes without saying that MOIN Filmförderung, Filmfest and CED comply with labour law, health and safety regulations and fair working conditions. The companies expect the same from their business partners. Compliance with Hamburg's minimum wage/printing matter w21/12930 of the Hamburg Parliament and compliance with collective labour agreements are ensured by Self-declarations proven.

Employees must comply with the internal company regulations. In all other respects, the regulations on secondary employment, the scope of the transfer of use and the use of facilities, vehicles, equipment or services apply, as regulated at MOIN Film Fund, in particular in the individual employment contracts and agreements on the transfer and use of objects. The current versions of the agreements are available on the internal network.
It is the responsibility of the management to provide employees with a hazard-free workplace and protective measures to ensure health and safety. MOIN Film Fund receives occupational health care from the AMD - Occupational Health Service of the Free and Hanseatic City of Hamburg. In addition, first aiders are regularly trained at MOIN Film Fund and Filmfest.

XIV Contributions to and from third parties

Gifts to third parties, including invitations to film screenings or other events and hospitality for third parties, may only be made as a business courtesy, must be appropriate and comply with the law. Similarly, the acceptance of invitations, gifts and other material and non-material benefits is only permitted within the framework specified by MOIN Film Fund, Filmfest and CED. Benefits may not influence business decisions or the behaviour of individuals. The Notice on the prohibition and exceptional acceptance of rewards and gifts applies accordingly.

XV Donations and sponsoring

In order to fulfil the requirement of impartiality, altruism and independence when accepting donations in the form of sponsorship, donations and patronage gifts, MOIN Film Fund, Filmfest and CED may only accept donations from third parties if their integrity is maintained, the appearance of impropriety is avoided, the budgetary rights of their shareholders, the Free and Hanseatic City of Hamburg and the State of Schleswig-Holstein are guaranteed, the financing of public tasks is transparent and any form of corruption and undue influence is prevented by flanking measures to prevent corruption. See Framework Directive on Sponsoring, Donations and Patronage Gifts for the Administration of the Free and Hanseatic City of Hamburg and its majority shareholdings dated 1 November 2013.

XVI Money laundering, corruption, fraud

Money laundering generally refers to the smuggling of illegally generated assets/money into the legal financial and economic cycle. These illegal assets/money are either the result of illegal activities (e.g. drug trafficking or tax evasion) or are intended to finance illegal activities. Money laundering is a criminal offence. If employees of MOIN Film Fund, Filmfest and CED suspect that money laundering may have taken place or if they are approached by third parties, they should immediately inform the management, their line manager or the compliance officer. MOIN Film Fund, Filmfest and CED will not enter into business relationships that could involve money laundering.

The same applies to corruption, i.e. the abuse of a position of trust in order to obtain a material or immaterial advantage to which there is no legally justified entitlement. Corruption includes bribery and corruptibility, accepting advantages and granting advantages. MOIN Film Fund, Filmfest and CED endeavour to meet the highest standards of transparency and responsibility.

XVII Protection of company property

All employees are responsible for the proper handling and protection of company property and work equipment. This also applies to confidential information. Business opportunities may only be used for the purposes of MOIN Film Fund, Filmfest or CED and not for personal gain.

XVIII. Competition and antitrust law

MOIN Film Fund, Filmfest and CED support the principles of free competition. A violation of the legal regulations for the protection of free competition can result in severe fines and thus jeopardise the existence of a company, including all of its jobs. Against this background, price fixing or the allocation of customers between competitors is prohibited. At MOIN Film Fund, Filmfest and CED, conflict situations could arise under competition and antitrust law, particularly in the context of procurement processes. Employees are obliged to comply with public procurement law and tendering procedures. If there is a suspicion of a breach of competition and antitrust regulations, the management, line manager or compliance officer must be informed immediately. See also Hamburg Public Procurement Act,Procurement Ordinance of the Free and Hanseatic City of Hamburg,Guidelines for awarding contracts for goods and services (except construction services), Hamburg conditions of application for the award of supplies and services.

Contact persons

Employees and business partners as well as funding recipients or applicants can contact their supervisors, management or the Compliance Officer if they have any questions about this Code of Conduct, need advice on possible conflicts of interest and/or wish to report violations of this Code of Conduct.

MOIN Film Fund has set up a compliance whistleblower system for all three companies. Reports can be directed to the compliance officers at MOIN Film Fund, Filmfest or CED. They confidentially record information on company-related criminal offences, improper business practices, other breaches of rules and deficits in business processes and report to the management or supervisory bodies via a compliance committee and, if necessary, seek legal advice or prosecution.

Contact is made via the whistleblower system on the respective MOIN Film Fund homepages,Film festivalorCED or directly to the current contact persons listed in the appendix to this Code of Conduct.