Placeholder Policy statement drafted for review. The reporting alias, the responsible person and the decision on an external ombudsperson still need to be confirmed. A formal internal reporting channel under the German Whistleblower Protection Act (HinSchG) is mandatory from 50 employees.
Our commitment
Cross-border staffing touches people at their most exposed: workers moving countries for a job, and clients relying on us to keep their site lawful. That makes compliance a condition of doing business rather than a document. This page sets out the standards we hold ourselves to and how to report a concern if we fall short of them.
Code of conduct
- Lawful employment. We supply workers only under a valid AÜG licence, with work authorisation verified, working time recorded and pay at or above the applicable minimum or collectively agreed rate.
- No fees from candidates. Our fee is paid by the employer. We never charge a worker for placement, and we act on any report that a partner has done so.
- Equal treatment. We select on qualification and suitability. We do not discriminate on grounds of origin, gender, religion, age, disability or sexual identity, in line with the General Equal Treatment Act (AGG).
- Anti-corruption. We neither offer nor accept payments, gifts or advantages intended to influence a business decision. Hospitality stays modest and is recorded.
- Honest representation. Candidates receive an accurate description of the job, the pay and the living conditions before they accept. Clients receive verification status without embellishment.
- Data protection. Personal data is processed only for the purpose collected, shared only with consent or a legal basis, and deleted when the basis ends.
- Supply chain. Recruitment partners are contractually bound to these standards, and we audit them. A partner that charges candidates or falsifies documents is terminated.
Reporting a concern
Anyone — an employee, a candidate, a client, a supplier or a member of the public — may report a suspected breach of law or of this code. Reports may be made in German or English, and may be made anonymously.
| By email | compliance@unicusglobalconsulting.com, read only by the person responsible for compliance |
| By post | Marked “Vertraulich — Compliance”, registered address |
| By telephone | number and hours, or a statement that written reports are preferred |
| External channel | Reports may also be made to the external reporting office at the Federal Office of Justice (Bundesamt für Justiz) under § 19 HinSchG |
How a report is handled
- Receipt is confirmed within seven days, unless the report is anonymous and no contact route is given.
- The person responsible for compliance assesses the report and, where warranted, opens an investigation.
- Feedback on the action taken follows within three months of the acknowledgement.
- Records are kept for three years and are accessible only to those handling the case.
Protection from retaliation
Reprisals against a person who makes a report in good faith are prohibited and are themselves a breach of this code. This includes dismissal, non-renewal of an assignment, transfer, withholding of work or any form of pressure. The identity of a reporting person is disclosed only where the law requires it, and never to the person the report concerns.
Knowingly false reports are a separate matter and may have consequences under employment or civil law.
Responsibility and review
Overall responsibility for compliance lies with the management. Day-to-day responsibility sits with role or name. This statement is reviewed at least annually and whenever the legal position or the size of the company changes materially.