Code of Conduct of the HEDRICH GROUP

1. Compliance with Applicable Laws

Compliance with all applicable laws is a mandatory foundation for all actions of the company worldwide. The present Code of Conduct, apart from other subjects, refers to areas of law that are of special relevance to the commercial conduct of the companies of the HEDRICH GROUP (hereafter called „We“) and their employees.

We will use best efforts to make sure that each employee knows and adheres to the legal prescriptions, which are relevant to him/her, as well as the company-internal rules. We expect him/her to seek legal advice from the senior management in case of doubt.

2. Commitment to Free and Fair Competition

Although we encourage our employees to act proactively in situations of competition, every staff member has to act fairly and in a legitimate way when representing our corporate interests. We respect the rules of free and fair competition to be a basic condition for a market economy, which is based on performance and capability, and act accordingly, both towards competitors and business partners.

Therefore, we reject any and all commercial actions that aim to create an economic advantage in a manner that contravenes competition law or using cartel agreements.
We leave no doubt that anti-competitive price arrangements or market allocations as well as the abuse of a dominant market position are prohibited and contradict our corporate policy. The competent national and international official authorities are notified by us of any business transfers or intended Joint Ventures in accordance with the legal prescriptions, and we observe all applicable execution prohibitions and obligations.

3. International Trade

We respect the rules of the international trade law. Without approval by the competent official authorities, we will not import or export any materials, products and technologies that are subject to legal control and require an export or import permit.

4. Our Products

Being a leading technological company, we develop innovative solutions and manufacture sophisticated products for individual requirements of our customers. We do research, development and work to the benefit of the people that use our products. Our products are subject to high demands on safety and quality. Fulfilling these demands is deemed part of our responsibility for the people that we are working for.

5. Environmental Protection

Protecting the environment is an essential part of a sustainable corporate development that we wish to use to keep our company competitive and at the same time accommodate our social responsibility.

Our company pledges to use natural resources responsibly and carefully. We encourage to develop and use environmentally compatible technologies in all ranges of our company and especially in our products. Observing the environmental standards in each of their applicable legal prescriptions forms an important part of our corporate policy in terms of environmental protection.

We expect our employees to promote a sustainable use of natural resources in their working environment in the company.

6. Safety at Work

Keeping all nationally relevant directives for the safety at work and of machinery in the company is fundamental for a responsible interaction. We steadily have in our focus the safety of our employees while at work and take all necessary precautions to meet the respective applicable legal regulations and in addition combat all detectable hazards in good time.

7. Privacy

We respect the rights of our employees and of third persons with regard to their personal data and take all necessary precautions to file, process and use any personal data only by strictly adhering to the respective regulations in effect.

8. Ban on Discrimination and Personal Interaction

As a matter of course, we respect the applicable national labour law, wherever we are working.
We access our employees and the employees of our business partners solely for defined-benefit characteristics. As a consequence, no one must be discriminated due to his/her nationality, race, skin colour, sex or other characteristics that are subject to applicable legal protection. The cooperation of women and men of all nationalities, cultures and religions is welcome.

Every staff member must be aware that any misbehaviour will be attributed to HEDRICH and can damage the company’s reputation on the market. We expect all employees to deal with their colleagues and third persons in a respectful, objective and fair way. We do not tolerate any personal insult or sexual harassment.

We respect the human dignity, the personal rights and privacy of all employees and people whom we have business contact to. We acknowledge the „Universal Declaration of Human Rights“ of the United Nations.

In our company, we promote a culture based on openness and honesty that allows inadequate behavior to be addressed frankly and cleared.

9. Protection of Business Secrets

Every employee undertakes to treat all business information confidentially, take precautions to prevent unintentional disclosure, and use the information only to the extent necessary for the sake of the business.

We expect all employees to deal with confidential information they have obtained from customers or business partners in the same way responsible as they would do with information of the own company, and in particular strictly adhere to non-disclosure agreements. All employees are forbidden to illegally seek for the knowledge of business secrets.

Access of unauthorized persons to internal information may cause serious damage to the company. Therefore, we take all necessary precautions to protect our internal data and information in data transfer and filing as well as all internal documents as made up, administered and filed according to our applicable guidelines.

10. Protection of Company Assets

We expect each employee to deal with the company’s property, especially consumables such as equipment, goods, office material, etc., responsibly and economically and not use it for any other but company-related purposes.

Innovative products and solutions are essential for the growth of our company. Inventions made by employees or third persons for the purpose of use by our company are to be legally protected to reasonable extent. No staff member is allowed to disclose any technical secrets to project partners or other third persons without special authorization and by securing secrecy.

Licenses for patents or know-how of the company must be negotiated and issued only in agreement with the competent lawyers and the senior management.

11. Behaviour in Case of Conflicts of Interests

All employees have to avoid any conflict between their private interests and the legitimate company interests when dealing with business partners, employees or thirds that have business relationships with Hedrich.

It must be made sure at any time that business relationships are exclusively determined by objective criteria. Same applies to decisions on personnel. Any on-purpose secondary employment of staff members for a company that we are in a business relation or potential competition to must be notified immediately.

No employee of our company is allowed to use his/her knowledge on internal procedures for the purpose of personal gain or gain to a third person.

12. Integrity in Relations to Suppliers, Customers and Official Authorities

We wish to convince our customers solely by the quality of our products and services. However, we assume that, as a gesture of good will or for the sake of good business relationships, it may be deemed adequate to offer to or accept from private customers and suppliers social amenities or exchange business courtesies.

However, these courtesies must neither be going beyond the scope of common courtesy or politeness, nor force the business partner or our employees into a position of obligatory dependence. In no case, we allow our employees to grant or accept benefits reflecting a commercial gain or bribery/corruption within the scope of the legal prescriptions. In case of doubt, legal advice is to be sought from the senior management.

We expect our employees to select suppliers by no other but the criteria defined by the company, in particular by the price, quality, technology, reliability, etc. Employees have to treat suppliers and customers in a fair way, without any preference or disadvantage for personal reasons.

We expect our employees to neither offer or grant any illegal advantages in business transactions or when acting with official authorities, nor claim or accept them from others.

13. International Business Activity

We offer products and services worldwide, making sure to heed the laws and prescriptions in every country that we are active in. We undertake to observe all relevant laws and prescriptions in the respective country where we are active in. Our employees that keep business contacts to international customers and suppliers must have understood the requirements and limitations for their business activity.

14. Communication and Transparency

We take care of true and complete notification to government agencies and business partners, which is in any way complying with the legal requirements. We take care that our conclusions entail a proper documentation of the business transactions heeding all internal and external accounting provisions.

We cooperate with official authorities and support them – under full reserve to our rights – in their work. Our employees have to observe applying law when acting with government agencies and make sure that the necessary transparency is given.

15. Social Commitment

We are aware of our social commitment and promote study and training facilities as well as social and cultural institutions and projects. The focus is on projects that are in connection with our core activities resp. can be realized locally within the scope of good neighbourhood.

We always keep an eye on the interests of the company and proprietorship, ensuring transparency in using funds and the pursued objectives. Personal initiative of our employees in social activities is explicitly welcome.

 
16. Realization of the Code of Conduct

Companies of the HEDRICH GROUP are to take all measures pertaining to corporate law or others that are required to implement the Code of Conduct in the respective company in accordance with the locally applicable law.

We take care that all employees know this Code of Conduct and we expect them to observe it. HEDRICH is available to all employees for advice and support to ensure this Code of Conduct is observed.

We value the support of all employees in observing the Code of Conduct and encourage them to notify any infringement. In principle such notifications should be addressed to the superior of the employee concerned or the human resources department of the respective company. However, it is also possible for every employee to address directly to the senior management in the headquarters of the HEDRICH GROUP.
 
Infringements are eliminated as quickly as possible and, as far as necessary, punished by the means available to us. We make sure that no employee will suffer any disadvantage from notifying infringements.