Code of Conduct

I. Scope of use

The rules of this Code of Conduct apply to all members of the Board of Directors and all employees of Jungfrau Railways and the Jungfrau Railways Pension Fund Foundation.
We also strive to ensure that our external partners comply with our Code of Conduct while performing their contractual activities.

II. Compliance culture

A. A sincere and honest corporate culture

We are not just employees, but also co-entrepreneurs. This idea is part of our corporate culture, which is characterised by identification, loyalty and exemplary commitment.

We are loyal and support corporate decisions. We are honest and fully identify with the company.

As co-entrepreneurs we actively contribute ideas and improvements, energy and team spirit. We take responsibility for our actions, face the consequences and are prepared to admit mistakes. We learn from our mistakes and we are ready to develop ourselves further.

We communicate openly, win people over with professional arguments, and cooperation is our top priority. We ensure the implementation of organisational changes and address the concerns of our employees.

B. Compliance with the law and internal regulations

We act responsibly in everything we do and abide by the law in all situations. In addition, we observe the internal rules and standards to which we have voluntarily committed ourselves. We are familiar with the rules applicable to us and follow them.

For us to make well-considered business decisions, we should always ask ourselves the following questions:

  1. Is the decision also in the long-term interests of Jungfrau Railways?
  2. Would I be embarrased if my decision or its consequences were made public?
  3. Will my ability to represent the interests of Jungfrau Railways to the outside world and to make appropriate decisions be impaired?
  4. On whom could this decision have a negative impact (customers, employees, owners, etc.)?
  5. Is the decision within my area of responsibility and Jungfrau Railways’ willingness to take risks?
  6. Are we doing "the right thing" and is it legal?

In the event of justified concerns or uncertainties, appropriate recommendations or instructions must be obtained from superiors or the Compliance Officer.

C. Individual responsibility

We continually familiarise ourselves with the applicable legal provisions and internal directives that are relevant to our professional activities.

Line managers provide support with the necessary information, instructions and training. Management makes sufficient resources available to this end and provides organisational support to line managers.

D. Avoidance of conflicts of interest

If we find ourselves in an actual or potential conflict of interest, we are required to disclose this situation to our line manager immediately. This also applies if only an apparent conflict of interest exists.

III. Dealing with business partners and third parties

A. Compliance with competition law

We compete fairly with other market participants on the basis of quality, service and price in compliance with applicable competition and antitrust laws.

B. Work assignments and contract awards / procurement

We select suppliers according to objective criteria, after comparing price, quality, performance and suitability of the products or services offered.

When awarding contracts and procuring goods or services, we treat all providers and suppliers equally and ensure a fair and transparent process. We observe the principles of non-discrimination, transparency and equal treatment and, where applicable, public procurement rules.

C. Fair competition

Our advertising should be fact-based and presented in a fair and appropriate manner. This means that at no time are false statements made about us or our competitors.

D. Bribery and corruption

We conduct our business on the basis of transparency and high quality of our services. To this end we reject bribery and other forms of corruption.

It is forbidden to offer or give a benefit with the effect or intention of influencing the specific decision of a person. As a matter of principle, we may not make gifts of money or other monetary benefits to public authorities and public officials or to private individuals who make current decisions relating to our business relationship with a company.

We do not accept gifts of money or other monetary benefits that are intended to influence us in our business decisions or that could restrict or influence our decision-making freedom.

E. Invitations and gifts

Gifts, entertainment (e.g. dinner invitations) and favours to or from public officials and private individuals or businesses are permitted only if they are customary and appropriate.

Gifts, entertainment and favours are generally considered customary and appropriate if they have a value of less than CHF 300 per person and per event and only occur occasionally.

Management may decide on exceptions in individual cases.

If the exception relates to a personal donation to a member of management, the Chairman of the Board of Directors of Jungfraubahnen Management AG must be informed. 

F. Cooperation with external partners

We expect our partners to conduct themselves correctly and to reject bribery or other forms of corruption. The specific requirements for our partners are set out in the respective contract.

Payments to agents must always be traceable (paper trail; documented by receipts and other documents).

G. Donations/sponsorship

With our public relations work, we take our responsibility as the largest employer and economic engine of the region seriously. Making contributions is also about promoting our image. Public relations work has an important role to play, which is why it is carried out actively and regionally in consultation with the heads of the operating units. Our target groups are the local and regional population, our employees, authorities, associations and tourism.

IV. Dealing with the environment

Jungfrau Railways operates an integrated sustainability management system. Sustainability is part of our corporate DNA. We take responsibility for the environment and society and thus contribute to raising awareness of sustainable action.

Sustainability |



V. Handling of data

A. Data protection and company information

Personal data may only be collected, processed or used insofar as this is necessary for clearly defined and legitimate purposes. We guarantee compliance with a high standard of data quality and technical protection against unauthorised access.

The use of data must be transparent for those concerned, and we safeguard their rights to information and correction and, if necessary, to objection, blocking and deletion.

Personal data should only be accessible to those persons who absolutely need it to carry out their work. If necessary, the company data protection officer of Jungfrau Railways ([email protected]) will be consulted.

B. Use of IT

Our business activities require powerful technologies for managing information. In connection with the confidentiality, integrity and availability of the IT system, we comply with the requirements of internal guidelines.

We do not use information technology and telecommunications resources that are intended for the performance of professional tasks, i.e. company equipment, software and systems and business software installed on our private equipment (BYOD), privately or, more specifically, for improper or illegal purposes.

C. Cautious handling of emails

We must be especially careful when writing emails and remember that electronic messages are permanent and can be modified or forwarded without our permission.

D. Social media

When using social media, we are aware that private and public communication regarding the company has an impact on the reputation of Jungfrau Railways. We also know that personal and business activities can overlap. We behave accordingly.

E. Confidentiality

Confidential information of the company is treated confidentially. All parties involved are obliged to comply with the legal and industry-standard requirements. This obligation continues to apply after termination of the contractual relationship.

VI. Asset management

A. Money laundering

We pay attention to whether there are any irregularities in payment transactions, especially in connection with large sums of cash and otherwise unusual transactions. In case of suspicion or uncertainty, the Supervisor or the Compliance Officer must be informed.

B. Subsidies

We use subsidies exclusively for the purposes for which they were applied for and approved. We think in an entrepreneurial manner when using such funds and therefore use them carefully and proportionately.

C. Handling third-party assets

We respect the assets of third parties. In particular, we also observe the legal regulations for the use of third-party intellectual property.

D. Handling Jungfrau Railways assets

We handle working materials, furnishings and all other Jungfrau Railways assets with care. We use the tools and equipment made available to us exclusively for business or other approved purposes and will not tolerate misuse or intentional damage.

We deal with services offered to third parties in an economical manner.

E. Building laws / spatial planning

We comply with building laws and obtain the necessary permits.

VII. Treatment of employees

A. Discrimination and harassment

We do not tolerate any form of discrimination or harassment.

Sexual harassment is prohibited. This also applies to bullying and other harassment at work. In particular, acts of revenge against persons who have reported harassment in good faith or have been involved in internal investigations of harassment are prohibited.

B. Health

We respect the health of our employees in the context of the employment relationship. We observe the relevant legal rules and regulations and offer working conditions that reflect this.

C. Occupational health and safety regulations

We all share the responsibility for creating a safe and healthy working environment in compliance with occupational health and safety regulations.

D. Protection regulations and safety

We comply with internal rules for health and safety at the workplace. To this end, we share responsibility for the health and safety of our colleagues.

The improper use of medicines and controlled substances, as well as the use of alcohol and illegal drugs in the workplace, are prohibited.

VIII. Society and authorities

A. Local engagement

We maintain active contact with local contact persons and promote local engagement.

B. Public offices and participation in governing bodies

We always ensure that mandates that we hold outside of Jungfrau Railways do not conflict with the interests of Jungfrau Railways.

C. Cooperation with authorities

As employees and managers of Jungfrau Railways, we cooperate fully in legal investigations conducted by us or the authorities. Legal rights to testify and the right to refuse to provide information as well as other procedural rights remain unaffected.

IX. Reporting procedures, infringements and sanctions

A. Reporting infringements

Infringements of this Code of Conduct must be reported to the direct line manager and the Compliance Officer so that the appropriate measures can be taken.

If there is reason to believe that the line manager him/herself is involved in the wrongdoing or is paying insufficient attention to the matter, employees can contact Legal Counsel (Executive Secretary) directly.

The reporting employee does not have to fear any disadvantages, provided that the report was made to the best of his or her knowledge and in good faith. Reports that are clearly unfounded must not be submitted.

B. Penalising infringements

In the event of infringements against the Code of Conduct, offenders must expect disciplinary measures and/or consequences under labour laws, up to and including dismissal without notice, regardless of the criminal consequences.

Interlaken, April 2023

Heinz Karrer
Chairman of the Board of Directors Jungfraubahn Holding AG
(for the Jungfrau Railway Group)

David-André Beeler
Chairman of the Board of Directors Berner Oberland-Bahnen AG