Code of Conduct and Ethics

of FEPS GmbH


The success of FEPS depends on the trusting relationships we have built over the years with our customers[1] , suppliers, government officials, communities and our employees.

Our partners expect us to provide outstanding solutions that solve their problems with a high level of quality and timeliness. You know you can rely on FEPS to act not only within the law, but also ethically, no matter what part of the world we operate in.

Compliance with the laws and regulations of the countries in which we operate is our top priority. We will not engage in any actions that could result in a violation of laws, nor will we allow such laws to be broken through inaction. Any exception is completely unacceptable, even if it is based on behavior or customs customary in the industry or region.

We are determined to run our business the “right way. But because we are a global company, sometimes the “right way” is not as easy as it seems. In a fast-moving, global business like ours, it can be difficult to make the right decisions and actually follow through. Our Code of Conduct helps us do this by identifying potential areas of risk or conflict and explaining their importance to our business.

We must all remember that our business decisions must be in accordance with the law, made in compliance with our Code of Conduct and Ethics, and in the best interest of our Company.

This Code of Conduct and Ethics is a set of guidelines that every employee should use to support our values of accountability, customer focus, integrity, innovation and people.

It is up to each of us to integrate these guidelines into our own behavior and to take our Code of Conduct into account when making decisions. In case of doubt, you are obliged to ask your supervisor or manager for advice and support.

By continually applying these guidelines, we will continue to enjoy the successes upon which this company was built and ensure our success in the future.


Okan Tombulca
Managing Director





Our Vision
Our vision is to be the world’s leading logistics company providing contingency and maintenance services to armed forces, peacekeeping operations and other government agencies.

Our mission
To provide logistics, life support and support services quickly and safely around the world.

Our core values
Our values determine how we do our work. We will not undertake or execute a project that compromises any of these values. When we commit to working in accordance with our values, we achieve superior solutions and maintain a leadership position in our industry.

We take responsibility for the actions and decisions of our company, our teams and individual employees. We are accountable to our customers, employees, suppliers and communities.

Each of our employees strives to conduct business according to the highest ethical standards. We demonstrate honesty and fairness to our customers, employees, suppliers and communities.

We offer a rewarding professional experience that promotes fairness, dignity and respect for all employees.

Our customers face difficult and dynamic challenges every day. Our innovative culture enables us to adapt our services to our customers’ needs. We translate our customers’ challenges into ideas that result in valued services that meet their needs and expectations.

Customer focus
All company decisions are centered on the needs of the customer. We strive to meet our customers’ expectations in terms of schedule, quality and value. Our customers are not just people, they are our partners.






Our company


Diversity of our employees


Equal opportunities and equal treatment are important cornerstones of a fair, unprejudiced and open approach. FEPS provides equal opportunities for all.

We believe that every employee should be treated with respect, courtesy and fairness. We promote respectful cooperation in a spirit of partnership, diversity and tolerance. The experiences, skills and insights of employees from different backgrounds and cultures enrich our business environment and ultimately contribute to our success. In this way, FEPS achieves the highest levels of productivity, competitiveness, innovation, creativity and efficiency.

We welcome and support people of all backgrounds and identities. This includes, but is not limited to, members of any sexual orientation, gender identity and expression, race, ethnicity, culture, national origin, social and economic class, educational background, color, immigration status, gender, age, height, marital status, political beliefs, religion, and mental and physical ability.


A safe working environment

FEPS is committed to providing a safe, healthy and drug-free work environment for all employees. The possession, use or sale of alcohol or illegal drugs is prohibited in the workplace. All employees are also prohibited from threatening, intimidating or harming others while working for the company. Possession of personal firearms or weapons is prohibited at all times while on a customer’s premises or while working for the Company.


Conflicts of interest

Each employee is required to avoid situations that create or appear to create a conflict between his or her personal interests and the interests of FEPS. Conflicts of interest may include, but are not limited to:

  • External supervisory board mandates
  • Off-site activities
  • Outside activity
  • External investments
  • Exploiting your position for personal gain
  • External relationships with suppliers, customers, competitors or partners of FEPS.

Finally, do not use other people to do indirectly what you are not allowed to do yourself.




Record keeping, record keeping and financial integrity

As FEPS, we can only build and maintain the trust of our contractual partners through proper accounting and correct financial reporting. Irregularities can have serious consequences for both FEPS and those responsible. We strictly adhere to the legal requirements for proper bookkeeping and accounting. Correctness and transparency are our top priorities.

This means that FEPS records, accounts, and financial statements must be maintained in reasonable detail, properly reflect the entity’s transactions, and comply with both applicable law and the entity’s system of internal controls. In addition, FEPS’ public financial reports must contain full, fair, accurate, timely, and understandable disclosures as required by law. The Company’s finance and accounting groups are responsible for procedures designed to ensure proper internal control and disclosure controls, and all employees should cooperate with these procedures.


Confidential information

All employees and service providers are responsible for protecting FEPS’ confidential information. It is this information that is responsible for our competitive advantage. As FEPS employees, we may have access to confidential and/or proprietary information related to our business, including but not limited to:

  • Product information, plans, specifications, designs and prices
  • Non-public financial information, including forecasts, budgets and data
  • Marketing or advertising plans or strategies
  • Business Strategies
  • Terms of contract
  • Customer preferences, customer lists or files
  • Preferences, lists or files of providers
  • Employment, personnel information and compensation data


Bribery; payments to government employees

Dealing with civil servants or holders of political offices, governments, authorities and other public institutions is often subject to special legal regulations.

All our contacts with officials and holders of political offices are conducted in strict compliance with all laws and regulations.

Our employees must not bribe anyone for any reason, whether dealing with governments or the private sector. The U.S. Foreign Corrupt Practices Act and similar laws in other countries prohibit offering or giving anything of value, directly or indirectly, to government officials to obtain or retain business. We may not make illegal payments to government officials ourselves or through third parties. Any single violation of this prohibition may have serious consequences and may permanently disqualify FEPS from awarding government contracts.


Use of FEPS resources

FEPS computer and communications resources, including computers, cell phones, voicemail and email, provide significant benefits, but also pose significant security and liability risks to you and FEPS. Each of us has a responsibility to use and care for these resources with care and to protect them from waste and misuse. Remember that you are acting as an agent of FEPS when you use FEPS computer or communications resources to access Internet services or send e-mails, IMs, text messages, voicemails, or other communications. Any improper use of these resources may reflect poorly on the Company, damage its reputation, and expose you and FEPS to legal liability.


Our business relations


Fair competition

FEPS believes in a free and open market. Fair and free competition is protected by the applicable competition and antitrust laws. Compliance with these laws ensures that competition in the market is not distorted, which is to the benefit and in the interest of all market participants.

We face strong competition in all our business activities and comply with the laws that support this type of market wherever we do business. FEPS enjoys measuring itself against its competitors, always complying with rules and regulations and observing ethical principles. We do not enter into anti-competitive agreements with competitors, customers or suppliers. If FEPS has a dominant position in the market, we do not abuse this position.

Antitrust and competition laws vary from country to country, are complex and not always intuitive. These laws touch and influence almost every aspect of our operations. Therefore, it is important that we are familiar with them and consult our supervisor to understand how they affect our daily work.


Business courtesies

It is sometimes customary to exchange business courtesies with third parties, such as gifts, meals, beverages, entertainment, recreation, honoraria, transportation, discounts, promotional items, facilities and equipment. Whether it is appropriate to offer or accept business courtesies depends on the circumstances and the parties involved. In any case, a business courtesy should never be offered or accepted if it could create a sense of obligation, interfere with your professional judgment, or appear to do so. Gifts of cash or cash equivalents (e.g., gift certificates, securities or below market value loans) in any amount are always prohibited. Also remember that it is never acceptable to ask for a business courtesy.


Prevention of corruption

FEPS and its employees will not offer or provide anything of value to anyone in return for a favorable decision or to secure favorable treatment. Anti-corruption laws prohibit offering or paying anything of value (including, but not limited to, money, stock, services, products, travel expenses, employment of related persons, and entertainment) to a foreign government official, political party, party official, or candidate for political office to influence official action, obtain or retain business, or secure an improper advantage. These laws also prohibit the preparation of inaccurate or false books and records and require companies to maintain adequate controls over accounting and company assets. Before making any payment or offering anything of value for any reason to a government official or a representative of a company or entity owned directly or indirectly by the government, you must consult with an officer.


Sustainability and protection of the environment and climate

The challenges of climate change are global, but at FEPS we can help make development a little more sustainable every day. We strive to create an environment that reduces the impact on the climate and ecosystems: we reduce the use and spread of hazardous substances, make efficient use of the earth’s resources, and work to increase recycling of materials, energy and water.

For FEPS, sustainability, environmental and climate protection, and resource efficiency are important corporate goals. We are committed to social engagement and strive to conduct our business in an environmentally sound manner. We ensure that our actions make a positive contribution to environmental and climate protection. To this end, it is our policy to comply with all environmental laws and regulations. Decisions on environmentally relevant measures, such as the disposal of hazardous and non-hazardous waste, must comply with applicable laws and environmentally sound practices.

Each and every one of us bears responsibility for the conservation of natural resources and the protection of the environment and climate through our individual behavior. All FEPS employees are aware of methods to conserve water and energy and will comply whenever possible. We will also reduce, reuse, and recycle as often as possible to reduce FEPS’ environmental impact.



[1] For reasons of better readability, the masculine form is used for personal designations and personal nouns. Corresponding terms apply in principle to all genders for the purpose of equal treatment. The abbreviated form of language does not imply any valuation.