Company principles

The foundations of our success

At Degler GmbH, we believe that ethical behaviour and economic efficiency are not mutually exclusive, but rather – quite the contrary – are interdependent.

Our goal is to create secure jobs in our region and offer our employees a safe working environment. To achieve this, we strive not only to secure market share, but also to ensure sustainability throughout the entire value chain.

We take care to show appreciation and respect to other people, groups and institutions. This means, for example, that we treat our business partners and employees fairly and as equals.

1. Introduction/Preamble

Degler GmbH is committed to environmentally and socially responsible corporate governance. We expect the same behaviour from all our business partners. We also require our employees to observe the principles of ecological, social and ethical behaviour and to integrate them into the corporate culture. Furthermore, we strive to continuously optimise our business activities, our products and our services in terms of sustainability and encourage our business partners to contribute to this in the spirit of a holistic approach.

Our Code of Conduct is based on national laws and regulations as well as international agreements such as the United Nations Universal Declaration of Human Rights, the Guidelines on Children’s Rights and Business, the United Nations Guiding Principles on Business and Human Rights, and the international labour standards of the International Labour Organisation. We expect our business partners to comply with all relevant laws and regulations as well as the requirements of national and international standards.

2. Principles of our corporate conduct

a) General principles

Scope

Our Code of Conduct sets out binding rules that must be observed by every employee of our company. The Code of Conduct is the basis and guideline for dealing with ethical and legal requirements in our daily work. In particular, the members of the management and all executives are responsible for actively implementing these rules. They must act as role models in every respect. Any employee can contact their supervisor or the management with questions or comments in this regard.

Integrity – Credibility – Transparency

We base our business activities and decisions on generally accepted ethical values, in particular integrity, credibility and respect for human dignity. We promote transparency, responsible leadership and control within the company in an appropriate manner.

Compliance with laws

Our company and all our employees comply with the laws and other legal regulations of the countries in which we operate. This also applies expressly to national, European and international product safety, machinery, waste and chemical legislation, as well as to embargo, customs and export control regulations.

Supply chain

We have formulated a separate code of conduct for our suppliers. We expect them to observe the guiding principles of the code of conduct, commit them to its implementation and require them to do the same in their supply chains.

Consumer

Where consumer interests are affected, our company complies with consumer protection regulations.

b) Conduct towards competitors, business partners and third parties

Competition and antitrust law

Our employees are obliged to comply with the rules of fair competition. In particular, any agreement or concerted practice with competitors on the following topics is prohibited:

• Prices and price components
• Terms
• Customers
• Delivery areas
• Quotas and capacities
• Agreed market withdrawals
• Coordination of planned innovations
• Boycotts

Our company respects the rules of fair and open competition and does not enter into any agreements that influence competition in an impermissible manner.

Corruption

Our company expressly rejects any form of corruption at home and abroad and avoids even the appearance of attempting to influence business decisions through unfair business practices. No employee may exploit the company’s business connections for their own benefit or for the benefit of others or to the detriment of the company. This means in particular that no employee may grant or accept any unauthorised private benefits, e.g. money, material assets or services, in the course of business that are likely to influence an objective decision. Every employee of the company is obliged to seek advice or assistance if they have any suspicions or legal doubts regarding the existence of corruption or white-collar crime. Advice or assistance can be obtained from the employee representative (MAV) and/or the management.

Tenders

If a contract is awarded on the basis of a formal tender, our employees shall neither discuss nor coordinate offers with other bidders. This applies to both public and restricted tenders, regardless of whether the award procedure is carried out by a public authority or a private entity.

Granting and accepting benefits, invitations and gifts

Invitations, such as to business meals or events, which are in line with recognised business practices and are appropriate, may be issued or accepted if they do not serve to give undue preference. The same applies to the acceptance or granting of gifts. If there is any doubt as to whether there is an objective reason or whether a gift is customary, the employee must consult the management in advance. This point is regulated internally.

Donations and sponsorship

Donations and sponsorship are only made on a voluntary basis and without expectation of anything in return. Donations and sponsorship must not be designed to covertly promote decisions in the interests of the company. Donations must be transparent. The recipient of the donation and the specific use made of it by the recipient must be known. It must be possible to account for the reason for the donation and its intended use at any time. Donation-like payments are prohibited. Donation-like payments are gifts that are only apparently granted as remuneration for a service, but whose value significantly exceeds the value of the service.

Public officials – political parties – elected representatives – consultants – agents

The granting of advantages of any kind to civil servants and other public officials as well as to representatives of state institutions, including indirectly through third parties, is prohibited regardless of their value. In the case of donations to political parties and organisations as well as to elected representatives and candidates for political office, the applicable laws shall be observed. The commissioning of consultants, agents and other intermediaries may not be used to circumvent the prohibition of bribery.

Money laundering

Our company does not tolerate money laundering. All employees are obliged to strictly comply with the laws on combating money laundering. Furthermore, they must immediately report any suspicious payment methods or other transactions that indicate money laundering to the management.

Tax law – customs law – foreign trade law

Our company prepares tax returns and declarations truthfully. All dutiable goods are properly cleared by us. Our company consistently complies with the legal requirements for export control and customs under foreign trade and customs law and ensures their proper implementation. The company expects its suppliers to provide export control and foreign trade data in a qualified and timely manner and to implement sufficient foreign trade and customs standards for security in the supply chain.

Avoidance of conflicts of interest

Our company expects loyalty from its employees. We take care to ensure that our employees do not find themselves in situations where their personal or financial interests conflict with those of our company or our business partners. Employees of our company must immediately report any personal interests that may arise in connection with their work to their line manager. Our employees are prohibited from running or working for a company that competes with our company. This also applies to the involvement of a close relative or life partner.

c) Handling of information

Trade and business secrets

Our employees are obliged to maintain confidentiality regarding trade and business secrets and other internal matters. This applies accordingly to information about contractual partners and customers that is not publicly available. This confidentiality obligation continues to apply after the end of the employment relationship.

Data

All our employees must strictly comply with the data protection regulations in accordance with the EU General Data Protection Regulation and national and international data protection laws. In particular, it is prohibited to process, disclose, make accessible or otherwise use protected personal data without authorisation for any purpose other than that required for the lawful performance of the respective task. This obligation to comply with data protection regulations shall continue to apply even after leaving the company.

Duty of truth

Reports and other written documentation must be prepared by our employees in a correct and truthful manner. This applies regardless of whether the documents are internal or external. Relevant records and supporting documents must comply with the principles of proper accounting and must always be complete and accurate.

d) Principles of social and environmental responsibility

Social responsibility – social commitment

Social responsibility is an indispensable part of our value-oriented corporate management and an essential factor in our sustainable corporate success. Our company contributes to the social and economic development of the country and region in which we operate.

Human rights – child labour

The company respects and supports internationally recognised human rights. In this context, we are also in constant dialogue with our suppliers to ensure that our products do not contain raw materials from conflict regions. Prohibitions on child labour and forced labour in any form are observed without exception.

Equal opportunities – prohibition of discrimination

Our company promotes equal opportunities for our employees. Discrimination against employees and third parties will not be tolerated. Our company takes a firm stand against unacceptable treatment of employees, in particular sexual or verbal harassment.

Employee rights – occupational safety – health protection

We fully recognise employee rights to the extent permitted by national law. Our company complies with applicable national laws and labour standards regarding fair remuneration and maximum working hours. This naturally includes compliance with all provisions of the regulations on a general minimum wage in Germany. Our company ensures fair working conditions overall. The prescribed occupational safety and health protection at the workplace is guaranteed within the framework of national regulations.

Environmental protection – climate protection

Sustainable environmental and climate protection and resource efficiency are important corporate goals for us. Both in the development of new products and services and in the distribution of our products and services, we ensure that all impacts on the environment and climate are kept to a minimum and that our products make a positive contribution to environmental and climate protection for our customers. Every employee is responsible for treating natural resources with care and contributing to the protection of the environment and climate through their individual behaviour.

e) Compliance with the Code of Conduct

Communication – Monitoring – Reporting of violations

We familiarise our employees with the contents of this Code of Conduct and explain the obligations arising from it. We also communicate the principles of the Code of Conduct to our business partners. We also undertake to monitor compliance with the Code on a regular basis. Every employee of the company is required to report any actual, potential or imminent violations of laws, internal regulations and this Code of Conduct to the management immediately. Reports of violations of this Code will be treated as strictly confidential and will not have any negative consequences for the reporting employee, unless a false statement has been made deliberately.

Processes – Guidelines – Instructions

The behavioural requirements set out in this Code of Conduct are binding for the company’s employees as part of their employment relationship and must therefore be observed at all times. The company will take all necessary steps to implement the fundamental values and guidelines contained in this Code of Conduct in all areas of the company through appropriate organisational measures and appropriate instructions, processes and guidelines.