Company and philosophy

Innovations in our society are not conceivable without the electronics and digital industry (German Electro and Digital Industry Association – ZWEI) and machine and plant engineering (German Mechanical Engineering Industry Association – VDMA). In both these industry sectors, small and medium-sized companies in particular use their products and applications to create future-proof solutions for protecting the climate, saving resources and securing jobs while contributing to social and economic development worldwide. All actions are in compliance with the applicable legal conditions and a fundamental responsible and ethical understanding that is set out in this joint Code of Conduct.

This Code of Conduct is based on a joint fundamental understanding of socially responsible corporate management in accordance with the following guidelines.

We, the undersigned company GEDA GmbH Mertinger Straße 60 86663 Asbach-Bäumenheim

Compliance with the applicable legislation and other legal regulations of the countries where we work is a matter of course for us. Where local legislation and regulations are less restrictive, our actions are based on the principles of this Code of Conduct. In the case of a direct contradiction between mandatory local legislation and the principles in this Code of Conduct, the local legislation takes precedence. We strive, however, to adhere to the contents of this Code of Conduct.

We have taken suitable compliance² measures to appropriately cover the following topics:

3.1 Corruption

We tolerate neither corruption, bribery nor blackmail. These practices prevent fair competition. Gifts that are linked to an intention or could give the impression of influencing business decisions or obtaining any other undue advantage are not promised, offered, granted, requested or accepted in our business relationships and we also accept no such promises. A particularly strict standard has to be applied to interactions with persons to whom special criminal and liability rules (e.g. office holders) apply.

3.2 Fair competition

We act in accordance with national and international competition and antitrust laws and do not participate in price fixing, in dividing of markets or in customer, market and bid rigging.

3.3 Prevention of money laundering

Money laundering refers to the procedure of infiltrating illegally obtained money or assets into the legal finance and economic cycle. We fulfil our legal obligations for the prevention of money laundering and do not participate in transactions that serve to conceal or integrate criminal or illegally obtained assets.

3.4 Protection of information and intellectual property

We protect confidential information and respect intellectual property. Technology and know-how transfer must be conducted in such a way that intellectual property, customer information, trade secrets and non-public information are protected. We adhere to the applicable legislation for protecting trade secrets and treat our business partners’ confidential information accordingly.

3.5 Data protection

We process, store and protect personal information in compliance with the legal regulations. This means that personal information is collected only for legal, previously defined purposes and in a transparent manner. We process personal information only if suitable technical and organizational measures are in place to protect this information against loss, change and unlawful use or disclosure.

3.6 Export control

We undertake to adhere to the applicable legal standards for export control – in particular approval requirements as well as export and credit support bans – when moving and exporting our goods.

3.7 Avoidance of conflicts of interest

We avoid internal and external conflicts of interest that could have an illegitimate influence on the business relationships. If this is not successful, we disclose these conflicts.

We maintain the health of our employees by taking suitable health and safety measures (e.g. implementation of a company health and safety management system) that appropriately cover the following topics:

• compliance with the applicable laws and orientation on international standards with respect to health and safety³;
• suitable workplace design, safety regulations and provision of suitable personal protective equipment;
• implementation of preventive checks, emergency measures, an accident reporting system and other suitable measures for continuous improvement;
• enabling of access to a sufficient volume of drinking water and access to clean sanitary facilities for all employees.

We ensure that all our employees have been instructed accordingly.

• The daily working hours, including overtime, do not exceed the respective legally permissible maximum limits;
• The weekly working hours, including overtime, do not exceed 60 hours even in exceptional cases, if such provisions do not exist;
• Employees have at least one whole day off per calendar week.

We adhere to and support compliance with internationally recognised human rights and

• respect the personal dignity, privacy and personal rights of each individual;
• protect and grant the right to freedom of speech and expression and;
• do not tolerate any unacceptable treatment of employees, such as physical or psychological hardship, sexual and personal harassment or discrimination.

We do not tolerate any child labour⁵. We do not employ anyone who cannot prove that they are at least 15 years of age and we ask for proof of age. In countries that fall under the exception for developing countries as per ILO Convention No. 138, the minimum age can be reduced to 14 years. We do not employ anyone for hazardous work who cannot prove that they are 18 years of age as per ILO Convention No. 182.

Forced labour, modern slavery or similar measures of false imprisonment are prohibited.⁶ Any work must be voluntary and workers must have the opportunity to terminate the employment.

We respect the employees’ right to freedom of coalition and freedom of assembly and the right to collective bargaining and wage negotiations⁷, in as far as these are legally permissible and possible in the respective country where we are active. If this is not permissible, we search for appropriate compromises for our employees.

We support equal opportunities and do not tolerate any discrimination⁸. We treat all people equally, regardless of sex, age, skin colour, ethnic origin, sexual identity and orientation, disabilities, religious affiliation, world views or other personal characteristics.

We act in accordance with the applicable laws and model our actions on international standards9 in order to minimise the negative impact on the environment and to continuously improve our activities for environmental and climate protection. We raise awareness for environmental protection and offer the necessary training measures. We have taken suitable environmental protection measures (e.g. implementation of a company environmental protection system) that appropriately cover the following topics:

• objective setting, definition and implementation of measures and their continuous improvement;
• environmental aspects such as reducing CO2 emissions, increasing energy efficiency and using renewable energies, ensuring water quality and reducing water consumption, ensuring air quality, supporting resource efficiency, reducing waste, correct waste disposal and responsible handling of hazardous substances for people and the environment.

We use due care to take measures for avoiding the use of conflict minerals in our products in order to prevent human rights violations, corruption and financing of armed groups and the like.

We expect our suppliers to adhere to the principles of this Code of Conduct or to apply equivalent codes of conduct. We also encourage them to enforce this Code of Conduct in their supply chains. We reserve the right to verify adherence to this Code of Conduct by our suppliers systematically and as the occasion arises, by means of, for example, questionnaires, assessments or audits. If there are subsequently doubts regarding adherence to this Code of Conduct, the supplier will be asked to take suitable countermeasures and to report the process to their responsible contact at our company. If necessary, the cooperation will be terminated.

If consumer interests are affected, we adhere to consumer protection regulations and to reasonable sales, marketing and information practices. Increased attention is paid to groups in need of special protection (e.g. young people or pregnant women).

We make suitable and appropriate efforts to continuously implement, document and apply the principles and values described in this Code of Conduct. All employees are made aware of the content of this Code of Conduct and are trained in the relevant topics as necessary. Violations of the Code of Conduct are not tolerated and can result in disciplinary action.

11.1 Communication

We use an open and dialogue-focused approach to communicate with employees, customers, suppliers and other stakeholders regarding the requirements of this Code of Conduct and its implementation.

11.2 Information about violations

We offer our employees and business partner access to a protected mechanism for confidentially reporting potential violations of the principles of this Code of Conduct.

If you have such information, please contact the following person/office directly or anonymously. lieferkettengesetz@geda.de

12. Signature