Code of Conduct for suppliers of the Siempelkamp Group

With this Code of Conduct, the Siempelkamp Group communicates its expectations of suppliers with regard to certain behaviors. As an external obligation, it forms the interface between Siempelkamp's corporate values and sustainability goals and the desired behavior of its suppliers. Against the background of legal requirements along the supply chain, Siempelkamp expects its suppliers to also commit their sub-suppliers to this Code of Conduct and to report on the implementation of the requirements by subsuppliers.

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1. Introduction

Siempelkamp is committed to ecologically and socially responsible corporate management. We expect the same behavior from all of our suppliers. We also expect our employees to observe the principles of ecological, social and ethical behavior and to integrate them into the corporate culture. We also strive to continuously optimize our business activities and our products and services in terms of sustainability and ask our suppliers to contribute to this in the sense of a holistic approach.

For future cooperation, the contracting parties agree to the validity of the following regulations for a joint code of conduct. This agreement shall form the basis for all future deliveries and services. The Supplier undertakes to comply with the principles and requirements of the Code of Conduct and to oblige its subcontractors and sub-suppliers to comply with the standards and regulations set out in this document.

This agreement comes into force upon signature or acceptance of an order from Siempelkamp. A violation of this Code of Conduct may ultimately be reason and cause for Siempelkamp to terminate the business relationship, including all associated supply contracts.

The Code of Conduct is based on national and international laws and regulations such as

• the 10 principles of the United Nations Global Compact Initiative,
• the United Nations Universal Declaration of Human Rights,
• the United Nations Guiding Principles on Business and Human Rights,
• the labor standards of the International Labor Organization, and
• the UNICEF Guidelines on Children's Rights and Business Conduct.

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2. Requirements for suppliers

Siempelkamp expects a plan to carry out a sustainability rating in a timely manner and/or a documented commitment from the supplier to introduce a sustainability management system.
Siempelkamp expects all suppliers to comply with minimum social, ecological and ethical standards. These include in detail, without being conclusive:

2.1 Social responsibility

Exclusion of forced labor

No forced labor, slave labor or comparable work may be used. All work must be voluntary and without threat of punishment. Employees must be able to terminate their work or employment relationship at any time. Furthermore, there must be no unacceptable treatment of workers, such as psychological hardship, sexual harassment and humiliation. The hiring or use of security personnel must be prohibited if persons are treated in an inhumane or degrading manner or are injured during their deployment or if freedom of association is impaired.

Prohibition of child labor

Child labor may not be used at any stage of production. Suppliers are requested to adhere to the recommendation of the ILO conventions on the minimum age for the employment of children. Accordingly, the age should not be less than the age at which compulsory education ends according to the law of the place of employment and in any case not less than 15 years. If children are found at work, the supplier must document the measures to be taken to remedy the situation and enable the children to attend school. Employees under the age of 18 may not be deployed for work that is harmful to the health, safety or morals of children. Special protection regulations must be observed.

Fair remuneration

The remuneration for regular working hours and overtime must correspond to the national statutory minimum wage or the minimum standards customary in the industry, whichever is higher. The remuneration for overtime must in any case exceed the remuneration for regular hours. If the remuneration is not sufficient to cover the costs of normal living expenses and to build up a minimum level of reserves, the supplier is obliged to increase the remuneration accordingly. Employees must be granted all legally prescribed benefits. Wage deductions as punitive measures are not permitted. The supplier must ensure that employees receive clear, detailed and regular written information on the composition of their remuneration.

Fair working hours

Working hours must comply with the applicable laws or industry standards. Overtime is only permitted if it is worked on a voluntary basis and complies with the applicable legal limits, while employees must be granted at least one day off after six consecutive working days. The weekly working hours may not exceed the legally permissible limits.

Freedom of association

The right of employees to form and join organizations of their choice, to engage in collective bargaining and to strike must be respected. In cases where freedom of association and the right to collective bargaining are restricted by law, alternative possibilities for independent and free association of employees for the purpose of collective bargaining must be provided. Employees must not be discriminated against on the basis of founding, joining or being a member of such an organization. Employee representatives must be granted free access to the workplaces of their colleagues to ensure that they can exercise their rights in a lawful and peaceful manner.

Prohibition of discrimination

Unequal treatment of employees in any form is not permitted unless it is justified by the requirements of employment. This applies, for example, to discrimination based on gender, national, ethnic or social origin, skin color, disability, health status, political beliefs, ideology, religion, age, pregnancy or sexual orientation. The personal dignity, privacy and personal rights of each individual are respected.

Health protection; safety in the workplace

The supplier is responsible for a safe and healthy working environment. The necessary precautionary measures against accidents and damage to health that may arise in connection with the work shall be taken by setting up and applying appropriate occupational safety systems. Appropriate measures must be taken to prevent excessive physical or mental fatigue. In addition, employees are regularly informed and trained on applicable health and safety standards and measures. Employees are provided with access to drinking water in sufficient quantities and access to clean sanitary facilities.

Preserving the natural foundations of life

The supplier may not, in violation of legitimate rights, withdraw land, forests or waters whose use secures the livelihood of people. The supplier must refrain from harmful soil changes, water and air pollution, noise emissions and excessive water consumption if this harms the health of people, significantly impairs the natural basis for food production or prevents people from having access to safe drinking water or sanitary facilities.

Complaints mechanism

The supplier is responsible for establishing an effective complaints mechanism for individuals and communities that may be affected by adverse impacts. Employees of the supplier can contact a designated complaints office at Siempelkamp. Employees who raise a complaint about violations of this Code of Conduct or relevant laws shall not be subject to any form of disciplinary action.

Dealing with conflict minerals

For the conflict minerals tin, tungsten, tantalum and gold as well as for other raw materials (such as cobalt), the supplier establishes processes in accordance with the Organization for Economic Cooperation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and expects its upstream suppliers to do the same. Smelters and refineries without appropriate, audited due diligence processes should be avoided.

2.2 Ecological responsibility

The following environmental aspects are to be considered, where relevant:

Dealing with air emissions

General emissions from operations (air and noise emissions) and greenhouse gas emissions shall be typified, routinely monitored, verified and treated as necessary prior to release. The supplier is also responsible for monitoring its emission control systems and is required to find cost-effective solutions to minimize any emissions. Greenhouse gas emissions are accounted for at least for Scope 1 & 2 in accordance with the internationally applied GHG Protocol. The aim of the accounting is to provide a meaningful balance sheet of the greenhouse gas emissions of the company and the products supplied.

Water use, especially in areas of shortage

The use of water as a resource must be limited to what is necessary and overloading of existing sources must be avoided. Avoiding evaporation and/or seepage is particularly relevant in water-stressed areas. The management of local water resources must take into account not only ecological but also social concerns. Permanent overuse of local water resources and disregard for third-party water rights must be strictly avoided.

Treatment and discharge of industrial wastewater

Wastewater from operational procedures, manufacturing processes and sanitary facilities must be typed, monitored, checked and, if necessary, treated before discharge or disposal. In addition, measures should be introduced to reduce wastewater generation.

Handling waste and hazardous substances

The supplier shall follow a systematic approach to identify, handle, reduce and responsibly dispose of or recycle solid waste. The prohibitions on the export of hazardous waste in the Basel Convention of March 22, 1989, as amended, shall be observed. Chemicals or other materials that pose a risk if released into the environment shall be identified and managed in a manner that ensures their safe handling, transportation, storage, use, recycling or reuse and disposal. Mercury shall be used in accordance with the prohibitions of the Minimata Convention of October 10, 2013 and persistent organic pollutants in accordance with the Stockholm Convention of May 23, 2001, as amended.

Reduce consumption of raw materials and natural resources

The use and consumption of resources during production and the generation of all types of waste, including water and energy, must be reduced or avoided. This is done either directly at the point of origin or through procedures and measures, e.g. by changing production and maintenance processes or procedures within the company, by using alternative materials, by saving, by recycling or by reusing materials.

Dealing with energy consumption/efficiency

Energy consumption must be monitored and documented. Economic solutions must be found to improve energy efficiency and minimize energy consumption.

Contamination of soils

The processes for providing the service must be designed in such a way that contamination of the soil (both temporary and permanent) is avoided. In addition to contamination, permanent damage to soil in the sense that subsequent use by agriculture or ecosystems can no longer take place must also be avoided. Contamination caused by unplanned events should be eliminated, primarily following the polluter pays principle. It should always be noted that soil contamination can always result in water contamination.