Code of Conduct of Effertz Tore GmbH

I. General Principles

1. Fundamental Understanding

Effertz recognises its social responsibility and is committed to fulfilling this responsibility in all its business activities.

Our activities, actions and decisions always follow the principle of legal compliance, i.e. compliance with the relevant and applicable legal and official requirements and regulations. We are also guided by the principles of the United Nations (UN Global Compact)

• Human rights (in line with the Universal Declaration of Human Rights): Protection of human rights, no complicity in human rights violations.
• Labour (in line with the principles of the ILO): e.g. protect freedom of association, abolish forced labour, child labour and discrimination.
• Environment: Support ecological and responsible behaviour, promote environmentally friendly technologies.
• Anti-corruption: Avoid corruption in all forms, including extortion and bribery.

2. Compliance with Laws (Legal Compliance Principle)

Effertz undertakes to comply with the relevant statutory regulations and official requirements as well as the other relevant provisions of the countries in which it operates in all its business activities and decisions (local legal compliance principle). Business partners are to be treated fairly. Contracts are honoured, whereby changes to the framework conditions are taken into account.

3. Focus on Generally Valid Values and Principles

Effertz bases its actions on generally accepted ethical values and principles, in particular integrity, honesty, respect for human dignity and non-discrimination.

II. Principles of Corporate and Social Responsibility

1. Human Rights

Effertz respects and supports compliance with internationally recognised human rights. In particular, it observes human rights in accordance with the UN Charter of Human Rights (Universal Declaration of Human Rights, General Assembly Resolution 217 A (III) of 10 December 1948).

These include, in particular, the five principles of the International Labour Organisation (ILO): Freedom of association, forced labour, child labour, discrimination and occupational health and safety. The resulting ten ILO core labour standards, which are intended to guarantee social standards within the framework of the World Trade Organisation for decent working conditions and adequate occupational health and safety, are listed here with the number of the corresponding international convention:

1. ILO 29 Forced labour (1939)
2. ISO 87 Freedom of Association and Protection of the Right to Organise (1948)
3. ILO 98 Right to Organise and Collective Bargaining (1949)
4. ILO 100 Equal Remuneration (1951)
5. ILO 105 Abolition of Forced Labour (1957)
6. ILO 111 Discrimination (Labour & Occupation) (1958)
7. ILO 138 Minimum age of employees (1973)
8. ILO 182 Prohibition of the deleterious effects of child labour (1981)
9. ILO 155 Labour protection and working environment (1981)
10. ILO 187 Framework for the Promotion of Occupational Safety and Health (2006)

2. Prohibition of Discrimination

Effertz rejects any form of discrimination within the framework of the applicable rights and laws. This refers in particular to discrimination against people on the basis of race, ethnic origin, gender, religion or ideology, disability, age or sexual identity.

3. Occupational Health and Safety

Effertz guarantees occupational health and safety in the workplace within the framework of national regulations.

This includes mandatory compliance with the relevant regulations of the Occupational Health and Safety Act (ASchG), the Occupational Safety Act (ASiG), the Working Hours Act (ArbZG), the sub-legal regulations (e.g. ASR) and accident insurance regulations (e.g. DGUV regulations and rules).

Effertz supports continuous further development to improve occupational health and safety.

4. Working Conditions

Effertz respects the right to freedom of association and assembly of its employees within the framework of the applicable rights and laws. Effertz complies with the labour standards with regard to the maximum permissible working hours and remuneration, in particular with regard to the remuneration level in accordance with the applicable laws and regulations.

Employees shall be protected from corporal punishment and from physical, sexual, psychological and verbal harassment. The privacy of employees is respected.

Youth labour protection and maternity protection laws are respected.

5. Environmental and Climate Protection

Effertz is committed to the goal of protecting the natural foundations of life for present and future generations. Laws and regulations enacted to protect the environment must be observed.

Effertz is committed to the transition to a sustainable economy and to limiting global warming to 1.5 °C in accordance with the Paris Agreement and takes this into account in its decision-making processes.

6. Communication

Effertz communicates in an open and dialogue-oriented manner about the requirements of this Code of Conduct and its implementation to employees, customers, suppliers and other interest and stakeholder groups.

III. Principles of Fair Competition

1. Prohibition of Corruption

Effertz rejects corruption and bribery. When dealing with business partners and state institutions, the interests of Effertz and the private interests of employees on both sides are kept strictly separate. Decisions are made free of extraneous considerations and personal interests. The applicable criminal law on corruption must be complied with.

The granting of personal advantages by Effertz and its employees to domestic or foreign public officials (such as civil servants or employees in the public sector) with the aim of obtaining advantages for Effertz or itself or third parties is not permitted.

Personal benefits of monetary value in return for unfair favouritism in business dealings between companies may not be offered, promised, granted or approved. Similarly, personal benefits of value may neither be demanded nor accepted in exchange for unfair favouritism in business dealings with business partners. The management and employees of Effertz may not offer, promise, demand, grant or accept any gifts, payments, invitations or services in business dealings that are granted with the intention of unfairly influencing a business relationship or where there is a risk of jeopardising the professional independence of the business partner. In principle, this shall not the case with gifts and invitations that are within the scope of customary business hospitality, custom and courtesy.

2. Conduct in Relation to Competitors

Effertz respects fair competition. It therefore complies with the applicable laws that protect and promote competition, in particular the applicable antitrust laws and other laws regulating competition.

In dealings with competitors, these regulations prohibit in particular agreements and other activities that unfairly influence prices or conditions, illegally allocate sales territories or customers or improperly impede free and open competition. Furthermore, these regulations prohibit unfair agreements between customers and suppliers that are intended to restrict customers in their freedom to determine their prices and other conditions for resale (price and condition fixing).

3. Business Secrets

Effertz shall respect and protect the business and trade secrets of others. Confidential information and confidential documents may not be passed on to third parties without authorisation or made accessible in any other way, unless authorisation has been granted, the information is publicly accessible or an enforceable decision by an authority or court requires this.

IV. Scope of Application, Implementation, Suppliers

1. Scope of Application

This Code of Conduct is a voluntary commitment by Effertz and applies to all subsidiaries and business units.

2. Implementation and Compliance

Effertz shall publicise the contents of this Code of Conduct and the obligations arising from it to its employees in an appropriate and effective manner. It shall take appropriate measures to ensure that this Code of Conduct is complied with.

In the event of non-compliance, appropriate corrective and remedial measures are taken, which are checked for effectiveness (validation) as part of the Effertz Management System (EMS).

3. Complaints Procedure

Effertz has set up an appropriate internal complaints procedure. This enables individuals to report risks and violations of the Code of Conduct. The receipt of the complaint is treated confidentially and anonymously in accordance with the statutory regulations. The person making the complaint receives a confirmation of receipt and a result of the procedure within the statutory deadlines.

4. Suppliers and Service Providers

We expect our direct suppliers and service providers (i.e. with whom business relationships exist within the framework of contracts) to comply with the Code of Conduct. In addition, they are requested to promote and comply with the Code of Conduct among their suppliers (upstream suppliers) to the best of their ability and to request that they also comply with the Code of Conduct. Effertz reserves the right to randomly check the application and effectiveness of this Code of Conduct at its direct suppliers and service providers as part of the management processes (e.g. through audits or surveys).

Mönchengladbach, 3. November 2023

Effertz Tore GmbH
Dr.-Ing. Claus Schwenzer