Code of conduct of the ORBIS Group

Rules of conduct for lawful and responsible behavior

1. Introduction/Preamble

The ORBIS Group is committed to ecologically and socially responsible corporate governance. We expect the same behavior from all our suppliers. We also expect our employees to observe the principles of ecological, social and ethical behavior and to integrate them into our 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.
This Code of Conduct is also aimed at all employees of the ORBIS Group. Each individual is expected to comply with it consistently. The term "employee" is not linked to a gender, but is to be understood as gender-neutral.
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. The contracting parties undertake to comply with the principles and requirements of the Code of Conduct and to support each other in doing so. The supplier undertakes to present this Code of Conduct to its subcontractors and to endeavor to contractually oblige them to comply with the standards and regulations listed. This agreement shall enter into force upon signing. A breach of this Code of Conduct may ultimately be reason and cause for us to terminate the business relationship, including all associated supply contracts.
The Code of Conduct is based on national laws and regulations such as the Supply Chain Duty of Care Act (LkSG), as well as international conventions such as the UN Civil Pact and the UN Social Pact, the Guidelines on the Rights of the Child and Business Conduct, the United Nations Guiding Principles on Business and Human Rights, the international labor standards of the International Labor Organization and the United Nations Global Compact.

2. Requirements

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.

Ban on child labor
We do not tolerate child labor. Suppliers are requested to comply with the recommendation from 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. Young workers under the age of 18 must not be employed for work that is harmful to the health, safety or morals of children. Special protective 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 shall be granted all legally prescribed benefits. Deductions from wages as a punitive measure 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 applicable laws or industry standards. Overtime is only permitted if it is voluntary and does not exceed 12 hours per week, while employees must be granted at least one day off after six consecutive working days. The weekly working time may not regularly exceed 48 hours.

Fair working hours
Working hours must comply with applicable laws or industry standards. Overtime is only permitted if it is voluntary and does not exceed 12 hours per week, while employees must be granted at least one day off after six consecutive working days. The weekly working time may not regularly exceed 48 hours.

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.

Dealing with conflict minerals
For the conflict minerals tin, tungsten, tantalum and gold, as well as for other raw materials such as cobalt, the company 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 suppliers to do the same. Smelters and refineries without appropriate, audited due diligence processes should be avoided.

2.2 Ecological responsibility

Treatment and discharge of industrial wastewater
Wastewater from operational procedures, production processes and sanitary facilities must be typified, monitored, checked and, if necessary, treated before discharge or disposal. In addition, measures should be introduced to reduce the generation of wastewater.

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.

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 making savings, 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.

2.3 Ethical business conduct

Fair competition
The standards of fair business, fair advertising and fair competition must be observed. In addition, the applicable antitrust laws must be applied, which in particular prohibit agreements and other activities that influence prices or conditions when dealing with competitors. These regulations also prohibit agreements between customers and suppliers that are intended to restrict customers' freedom to determine their own prices and other resale conditions.

Confidentiality/data protection
The supplier undertakes to meet the reasonable expectations of its client, suppliers, customers, consumers and employees with regard to the protection of private information. The Supplier shall comply with data protection and information security laws and regulatory requirements when collecting, storing, processing, transferring and disclosing personal information.

Intellectual property
Intellectual property rights must be respected; technology and know-how must be transferred in such a way that intellectual property rights and customer information are protected.

Integrity/bribery, taking advantage
The highest standards of integrity must be applied to all business activities. The supplier must have a zero tolerance policy against all forms of bribery, corruption, extortion and embezzlement. Procedures for monitoring and enforcing standards shall be implemented to ensure compliance with anti-corruption laws.

3. Implementation of the requirements

We expect our suppliers to identify risks within their supply chains and to take appropriate measures. In the event of suspected violations and to safeguard supply chains with increased risks, the supplier will inform us promptly and, if necessary, regularly about the violations and risks identified and the measures taken.
We check compliance with the standards and regulations listed in this document using a self-assessment questionnaire and risk-based audits at the supplier's production sites. The supplier agrees that we may carry out such audits once a year or for specific reasons to verify compliance with the Code at the supplier's premises during normal business hours after reasonable advance notice by persons authorized by us. The supplier may object to individual audit measures if these would violate mandatory data protection regulations.

Complaints procedure
The supplier must pass on information received from us regarding accessibility, responsibility and the implementation of a complaints procedure to its employees in an appropriate manner. The complaints procedure must be accessible to employees while maintaining confidentiality of identity and effective protection against discrimination. If no notice is given, the supplier itself is responsible for setting up an effective grievance mechanism at company level for individuals and communities that may be affected by negative impacts.
If a breach of the provisions of this Code of Conduct is identified, we will inform the supplier immediately in writing and set him a reasonable grace period to bring his conduct into line with these provisions. If a remedy is not possible in the foreseeable future, the supplier must notify us immediately and, together with us, draw up and implement a concept with a timetable for ending or minimizing the violation. We have the right to temporarily suspend the business relationship in the meantime. If the grace period expires without result or the implementation of the measures contained in the plan does not remedy the situation after the expiry of the timetable and no milder means are available, we may terminate the business relationship and terminate all contracts. A statutory right to extraordinary termination without setting a grace period, in particular in the case of willful and very serious violations, remains unaffected, as does the right to compensation.

4. Awareness and consent of the supplier

By signing this document, the supplier undertakes to act responsibly and to comply with the principles/requirements listed. The supplier undertakes to communicate the content of this code to employees, agents and subcontractors in a way that is understandable to them and to take all necessary precautions to implement the requirements.