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Code of Conduct

Code Standards

Being an internationally active company we need to ensure that all employees and staff who contribute to our success, are familiar with, and fully understand, our human and employment rights Code of Conduct.

No persons who work with or for us should experience mental or physical harm in any manner. For this reason we have a ‘Code of Conduct’ which illustrates what is required of us all, in our internal behaviour and in our business relations.

The demands and minimal standards, which are written into this code, are in accordance with ‘The International Labour Organisation (ILO / IAO) and all known United Nations (UN) standards.

Although we are aware, that our business partners, possibly derive from cultural and political backgrounds, which may differ from our own values, there are established definitions and universal human rights, that under all circumstances must be observed and safeguarded.

We take care when making decisions and in our behaviour to observe the fundamental requirements contained in this document. Every and any violation of these standards that comes to our attention, will be dealt with, within the framework of influence open to us.

Our company guarantees the observance of this code on behalf of all our employees, irrespective of the contractual basis of their undertaking. Similarly we expect this of our suppliers. National ‘Codes of Conduct’ which are more robust will also be adhered to in all cases.

Our Colleagues of Employment

will conduct themselves, according to their best knowledge and conscience, in harmony with the laws of the land in which we have business relations,
observe trusting, working relationship as a guiding principle of our association,
base their decisions upon objective and measurable criteria,
accept no gifts or presents, irrespective of whatever form they are presented,
document all results of contractual negotiation
declare the content of contracts and necessary formalities openly and unconditionally to our business partners.

Environment

We accept responsibility, to negotiate and behave as an environmentally aware company whereby negative environmental consequences of our business activities, due to the use of responsible and industrially acceptable methods, will be minimal. We promote the preservation of the environment, recycling, and energy conservation, clean air, clear water, the reduction of waste and regeneration of natural resources of the earth. We abide by all environmental rules and related legislation in those countries in which we are actively engaged.

Taking responsibility for our colleagues, the sensible use of resources and industrial ‘know-how’ are all clearly apparent in our sustainable initiatives.

Sustainability

Financial sustainability is a fundamental element of thinking for futuristically minded, company leadership. We endorse comprehensively the relevant themes of economy, ecology and socialism. In close cooperation with Witten/Herdecke University we have relevant themes, such as climate, energy, resources, quality and user protection, demographics and community responsibility, wholly and with consequence, in our sights. That is why we understand our sustainability being a continuous process of collective, authentic responsibility.

Our Suppliers

We fundamentally endeavour to build upon and care for our business relationships. We expect our business partners to respect this ‘Code of Conduct’, to maintain social standards and in an honest manner to adhere to the laws of the land. Our suppliers know that this code, or a similar document, is implemented throughout the value added chain. In concrete terms we expect our business partners to fulfil the following requirements:

Information

Suppliers should ensure their company is in agreement with this code and make it fully accessible to their working membership.

Adherence to lawful Instructions

Our business partners should adhere to all national lawful regulations, in particular employment and social rights regulation as well as environmental regulation.

Controls

We expect all our business partners to implement provisions for the compliance of all such written standards. For the purposes of control we would be pleased to arrange for neutral auditors to be called in.

We, or a third party nomination, are authorised at any time and without warning, to visit all production sites of our business partners and their sub-contractors for the purpose of control.

We reserve the right to terminate business relationships in the event there are serious breeches of fundamental human rights, calculated breeches of standards, systematic falsification and / or if there is a repetitive failure in willingness to cooperate, being apparent.

Standards of Work

1. Working Atmosphere

All employees are to be treated with respect and dignity. Any and every form of bodily castigation, psychological, sexual or verbal harassment, mishandling and any and every form of intimidation is forbidden. Disciplinary measures are to be in accordance with national legislation and the International Law of Human Rights.

2. Working Time

Working times must be set in accordance with common law. In no cases should employees work for more than 48 hours in a regular working week. Overtime, that is agreed within the framework of the appropriate regulation, must be compensated. All employees must, in normal circumstances, have at least 24 hours free-time after working for 6 consecutive working days.

3. Renumeration

All employees are to receive payment for work completed within normal working time, which at least, is in accordance with the lawful minimum wage.

4. Conditions of Employment

Employment must be documented in detail on a formal basis e.g. an employment contract or a working agreement. These documents must contain information about the work and working conditions, including remuneration, when payment is to be made, proficiency, holiday allowances and notice of dismissal or termination details.

5. Health & Safety at Work

The place of work must not be a source of danger to an employees health and safety. A safe and clean working environment should be available. Good health at the working place and safety practices, are measures which are demanded in advance in order to avoid accidents and injury at work or resulting from the use of company machines or tools. These safety practices and procedures must be communicated to the employee. Similar principles are apply to all social facilities and company premises, in so far as the company is responsible for their availabilty.

6. Enforced Labour

All employees must take up their work on a voluntary basis and continuing to work must be in accordance with his / her wishes. Any and every form of enforced labour, debt bondage or prison-employ, is forbidden.

7. Child Labour

Child labour as defined by the ILO and UN convention or national regulations, is forbidden. The ILO and Un recognised age limit for employment is certainly not below the conpulsary school age and not in any case under 15 years (or 14 years, inasmuch as that is permitted due to a national rights agreement with the ILO accord 138). Every supplier will be made directly responsible for violations of the regulation concerning child labour, should this be established as prevalent in the supplier’s production premises or in any subcontracted company’s production premises. The regulations relating to the protection of children being engaged in child labour, must be observed.

8. Discrimination

All employees must be similarly treated. Discrimination based on sexuality, religion, age, race, social background, caste, nationality, ethnic and national origin, membership in an employees organisation, a disability, sexual or political orientation, or any other personal amplification, will not be tolerated. The instructions of the AGG apply.

9. Freedom of Unionism

It is every employers right to establish a workers organisation (or Union) of his / her choice or to join a similar collective negotiating body. Should it be the case that these unionist rights are limited due to national law, employees must be allowed to demand their interests are represented directly in exchanges with the employer.

10. Corruption

Our business relationships and decisions are based on performance and achievement. For this reason we never offer a third party e.g. a public authority or customer, either direct or indirect, an item or assistance of value in order to influence this person’s business decision (favourably) or to gain an advantage. Our employees neither accept any item or assistance, which could in any circumstance be identified as influencing decision making processes. The fundamental principles of law e.g. The ‘Fight Against Corruption’, the law representing worldwide problems; ‘International Bribery’ and the UN convention (UNCAC) are to be observed at all times.

11. Cartel

Unfair labour practices, which are intended to provide a disadvantage to an adversary, the user or any alternative marketing representative is not only futile interference, it is illegal, we will not tolerate such behaviour.

All forms of coordination or coordinating behaviour with adversary’s, which has the aim or cause to derogate is forbidden. To impose constraints upon customers or suppliers by structuring prices or imposing upon suppliers relationships with their business partners, is prohibited. Malpractice in a monopolistic position is forbidden.

Cooperation and Development

In addition to adherence to these business standards we expect our business partners to be cooperative and show a willingness in supporting our activities toward a concrete development of these written standards.

Even though a violation by a supplier may occur and has made it necessary, to cease business relations, we offer our support in the search for solutions to difficult situations and for the development of the supplier, whereby the recovery of the business relationship may be possible.

We consider it a question of prudence that a suitable period of time should elapse for the development of a partners performance, in relation to their compliance of individual points in the standards.

Complaints / Questions

We are always available to answer questions in regard to individual, details. Should schooling of selected themes be necessary, we are ready to offer our support in this regard also.

Any and every person who becomes aware of violations of these standards is obliged to make immediate contact with an employee representative or member of staff and, so far as it is possible to do, give a detailed, informed account of the event. A direct path to senior management is always available.

Declaration of Principles

Our Declaration of Principles in the context of the act on Corporate Due Diligence Obligation in Supply Chains (Lieferkettensorgfaltspflichtengesetz) can be found here.