Responsibility

1 Basic understanding and validity

We, the undersigned company, see ourselves as part of the societies in which we do business and are committed to socially responsible corporate governance by taking into account the direct and indirect effects of our business activities on society and the environment and constantly endeavouring to achieve an appropriate balance of interests in economic, social and environmental terms. We act in accordance with generally recognised values and principles such as integrity and legality and, in particular, observe internationally recognised human rights and labour standards as set out in the Code of Conduct. We share the objectives and content of the Code of Conduct and will make every appropriate and reasonable effort within the scope of our respective legal and actual possibilities to fulfil the voluntary commitment on an ongoing basis at all our company locations in Germany and abroad. If existing national regulations contradict the content of the Code of Conduct or the national context makes it impossible to comply with them without restriction, we will look for ways to fulfil the requirements of the Code of Conduct as far as possible.

2 Human rights and labour standards

We respect human dignity and respect internationally recognised human rights, as set out in particular in the United Nations (UN) Universal Declaration of Human Rights (UDHR).¹ and are set out in the United Nations Guiding Principles on Business and Human Rights.² and the OECD Guidelines for Multinational Enterprises³ be addressed.

We also comply with the internationally recognised labour standards of the International Labour Organisation (ILO), as set out below in the Code of Conduct. In all our business activities, we always endeavour to neither cause nor contribute to human rights violations. We expect the same from our business partners. Where necessary and possible, we support our supply partners in this endeavour.

2.1 Employment relationships

We treat our employees with respect. We reject any form of unlawful punishment, abuse, harassment, intimidation or other unworthy treatment of employees. We adhere to the applicable labour law in all employment relationships and expect the same from our contractual partners. At the beginning of the employment relationship, employees must be provided with comprehensible information about the essential working conditions, including their rights and obligations as well as working hours, remuneration and payment and accounting modalities. We respect and protect the right of employees to terminate their employment relationship in compliance with the relevant notice period.

2.2 Prohibition of child labour and protection of young workers⁴

We do not tolerate child labour and observe the applicable legal minimum age for admission to employment. In any case, we do not employ persons under the age at which compulsory schooling ends under the law of the place of employment or under the age of 15. We expect our contractual partners to have appropriate means of determining age in order to prevent child labour. If child labour is detected, all necessary measures must be taken immediately to ensure the welfare, protection and development of the child.

2.3 Prohibition of forced labour⁵

We reject all forms of forced or compulsory labour, including any form of debt bondage, servitude, slavery or practices similar to slavery, human trafficking or other involuntary labour and services that are incompatible with internationally recognised labour and social standards.

2.4 Remuneration⁶

We adhere to the legal or statutory regulations when remunerating labour services.
-where applicable, the provisions of collective agreements. We guarantee that the wages we pay do not fall below the applicable statutory or collectively agreed minimum wage or the minimum wage customary in the industry. In countries or regions without a statutory or collectively agreed wage framework, we pay particular attention to ensuring that the wages paid for regular full-time work are sufficient to fulfil the basic needs of the employees. We do not tolerate wage deductions that are not authorised by law, including wage deductions as a disciplinary measure.

2.5 Working hours⁷

We comply with the statutory or applicable collectively agreed provisions on working hours, including overtime, rest breaks and holidays. In any case, we ensure that

• the regular weekly working time does not exceed 48 hours plus a maximum of 12 hours of overtime per week,

2.6 Freedom of association⁸

We respect the right of employees to freedom of association, freedom of assembly and the right to collective bargaining, insofar as this is legally permissible and possible in the respective country of employment. If this is not permitted, we seek appropriate compromises for our employees.

2.7 Diversity and inclusion, prohibition of discrimination⁹

We promote a working environment that enables inclusion and in which the diversity of our employees is valued. We are committed to equal opportunities and reject any form of discrimination or unjustified unequal treatment in employment, for example on the basis of national and ethnic origin, social background, health status, disability, sexual orientation, age, gender, political opinion, religion or belief. We also take into account the principle of equal pay for male and female workers for work of equal value.

2.8 Health and safety in the workplace¹⁰

We comply with national and international occupational health and safety standards and ensure a safe and healthy working environment in order to protect the health and safety of our employees.

employees, protect third parties and prevent accidents, injuries and work-related illnesses. This includes regular risk assessments of workplaces and the implementation of appropriate hazard prevention and precautionary measures, including the provision of suitable personal protective equipment. We ensure that our employees are trained in all relevant health and safety topics.

3 Ecological responsibility

The protection and preservation of the natural foundations of life concerns and obliges us all. With this in mind, we carry out our business activities taking ecological aspects into account and are committed to the goal of a climate-neutral future.

3.1 Protection of the environment and climate

We fulfil our environmental responsibility by complying with the applicable legal requirements and recognised standards for environmental and climate protection and by making efforts to continuously improve the impact of our business activities on the environment and climate. We have taken appropriate measures that are based on legal and internationally recognised standards and cover the following topics, among others:

• Professional and responsible handling of hazardous substances and other chemicals as well as waste, including disposal;
  
  
• Efforts to reduce or avoid waste and minimise emissions from operational processes (e.g. waste water, exhaust air, noise, greenhouse gases);
  
  
• Conservation of natural resources, for example through measures to save water, chemicals and other raw materials;
  
  
• Promoting the use of circular and other climate and environmentally friendly technologies, processes, raw materials and products;
  
  
• Efforts to increase energy efficiency and the share of green and renewable energies in energy consumption at our company locations.

3.2 Animal and species protection

We observe the principles for the protection of animals and biodiversity and organise our business activities accordingly. The keeping and utilisation of animals must comply with the applicable legal animal welfare requirements and be species-appropriate. The Washington Convention on International Trade in Endangered Species¹¹ must be observed.

4. Ethical business practices and integrity

We only pursue legitimate business objectives and practices and only maintain business relationships with reputable partners. We behave fairly and respectfully towards our business partners and customers. We respect the different legal, economic, social and cultural backgrounds and circumstances of the countries and regions in which we operate. We always base our business activities on universally recognised ethical values and principles, including integrity and respect for human dignity. We are in favour of free and fair global trade and comply with the laws and regulations of the countries and regions in which we do business.

4.1 Corruption¹², trade control, money laundering

We reject all forms of bribery and corruption and avoid even the appearance of such behaviour - be it in the form of granting or accepting improper import and export controls and comply with the legal requirements for the prevention of money laundering.

4.2 Fair competition

We are in favour of free and fair competition. We do not tolerate any anti-competitive agreements and ensure that we act in accordance with the applicable antitrust laws. We reject competitive advantages through unfair business practices.

4.3 Personal data, protection of confidential information and intellectual property

We respect the personal rights of our employees, business partners and customers and comply with the applicable legal and regulatory requirements for the processing of personal data and information security when handling personal information. We take great care to ensure that business secrets and other confidential information entrusted to us by our business partners and customers are adequately protected against unauthorised acquisition, use and disclosure, but at least in accordance with the relevant statutory provisions on the protection of business secrets. We respect the intellectual property of our business partners, customers and other third parties and ensure that sufficient precautions are taken to protect intellectual property rights when transferring expertise and technologies.

4.4 Consumer interests

Where our products and services affect the interests of consumers, we have taken appropriate measures to ensure the safety and quality of the products or services we offer. In doing so, we ensure that our products or services comply with the relevant statutory consumer protection provisions. As part of our information and sales measures, we take consumer interests into account by applying fair business, marketing and advertising practices and promoting consumer education. We pay particular attention to the interests of children, senior citizens, people with disabilities and other vulnerable consumer groups.

5 Realisation

We make suitable and reasonable efforts to continuously comply with the contents of the Code of Conduct at all of our company's locations. We have established suitable measures and processes for this purpose and document their implementation within the company in an appropriate manner. The company management is informed at regular intervals about the implementation and work of the responsible departments and persons.

5.1 Communication and training

We communicate the content of the Code of Conduct to our employees, business partners and other key stakeholders and train our employees on individual topics of the Code of Conduct as required. We expect our employees to comply with the Code of Conduct.

5.2 Expectations of our supply chains, control measures

The content of the Code of Conduct also reflects our expectations of our supply partners and other contractual partners in our supply chains. In this respect, we expect them to be guided by the contents of the Code of Conduct or to apply a comparable code of conduct and encourage them to demand this expectation from the contractual partners in their supply chain.

As a matter of principle, we focus on long-term business relationships based on partnership. We therefore identify and check our contractual partners in an appropriate manner before we enter into a supply relationship, e.g. through self-disclosure, supplier evaluation or similar. We reserve the right to monitor our suppliers' compliance with our expectations, e.g. by means of auditing. If serious violations are found, we reserve the right to take appropriate contractual consequences, including the termination of the business relationship. In any case, we expect that any violations identified will be responded to with suitable preventive or remedial measures.

5.3 Indication of violations

We take every violation of the Code of Conduct seriously. In the event of reports of violations, we initiate measures for proper and confidential clarification and, if necessary, take appropriate countermeasures in the sense of remedial or preventive action.

1 Universal Declaration of Human Rights
2 UN Guiding Principles on Business and Human Rights
3 OECD Guidelines for Multinational Enterprises
4 ILO Conventions No. 138 and 182
5 ILO Convention No. 29 and 105
6 ILO Conventions 26 and 131
7 ILO Convention 1; ILO Recommendation 110
8 ILO Conventions 11, 87, 98, 135 and 141
9 ILO Conventions 100, 111 and 159; ILO Recommendation 165
10 ILO Conventions 155, 183 and 184; ILO Recommendation 164
11 Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES).
12 United Nations Convention against Corruption