Code of Conduct of Wirthwein SE and its subsidiaries
Foreword
Wirthwein SE and its subsidiaries are among the world's leading manufacturers of high-quality and complex plastic parts and tooling. With Winkler Design, the group is also active in the field of interior design.
In our guidelines, we commit ourselves to acting responsibly and lawfully towards our employees, business partners and the public. In addition to the applicable laws and internal agreements, these principles constitute a globally binding set of rules for sustainable and responsible action in the corporate organization.
Scope of application
These guidelines are binding for all employees of Wirthwein SE and its subsidiaries as well as for suppliers, service providers and other partners worldwide and can be understood as a uniform internal set of rules for dealing with employees and partners. Each individual is responsible for his or her own actions and decisions.
1. Business Integrity
It is our policy to comply with all applicable laws and regulations. We are guided by international conventions and guidelines, such as those of the UN Global Compact1 [1] (UNGC), the International Labor Organization[2] (ILO) and the OECD[3].
Stricter standards than those described in this Code of Conduct may exist in individual countries, businesses or markets. In the event that national and/or international laws, regulations or industry standards provide for additional and/or more stringent requirements, these must be followed.
Prohibition of Corruption, Bribery and Personal Gain
Free competition is a cornerstone of our free society and market economy and must always be protected and upheld in our business activities. Compliance with applicable anti-corruption laws is a prerequisite, and any influence on competition in the form of corruption or bribery must be rejected and refrained from at all times.
The selection of our suppliers is based exclusively on quality, delivery reliability, price, sustainability and optimal problem-solving expertise. At the same time, we win our business through quality, cost awareness and innovation.
None of our employees may offer (active bribery) or accept (passive bribery) unlawful advantages. This includes, but is not limited to, payments of money or other benefits that influence free decision-making in order to gain an advantage for oneself or others.
Actions that influence competition are a violation of our policies and will result in sanctions. This includes self-dealing, unless the Company has granted an exemption from the self-dealing prohibition.
Avoiding Conflicts of Interest
Conflicts of interest occur when personal interests interfere with the interests of the Company. Conflicts of loyalty, where personal interests may conflict with the interests of the Company, must be avoided. In addition, employment must not be used for personal gain and actual or potential conflicts of interest must be reported.
Free and Fair Competition
We will always act as a fair and responsible market participant and comply with all relevant competition and antitrust laws to ensure fair competition. In particular, we do not enter into illegal agreements or arrangements with competitors, suppliers, customers or other third parties, and we do not abuse any dominant market position we may have.
Prohibition of Money Laundering
Black money is consistently excluded from our business. We work only with reputable suppliers, service providers and trading partners who comply with applicable laws. We focus on transparency in our business relationships to prevent criminal activity. Any involvement in money laundering and terrorist financing is illegal and will be prosecuted.
Intellectual Property Protection
Intellectual property will be respected and honored. Information about patents, trademarks, trade secrets and other intellectual property rights must be kept confidential. In addition, we do not support infringement of the intellectual property of others and promote fair business practices.
Privacy/Security Compliance
All employees are required to ensure the right to informational self-determination, the protection of personal data, and the security of all business information and personal data in all business processes in accordance with legal requirements and applicable privacy and information security laws. Data breaches must be reported and appropriate security measures must always be taken to protect data from unauthorized access.
Compliance with Foreign Trade Laws
We are committed to strict compliance with all applicable laws and regulations governing the import and export of goods, services and information. We adhere to relevant sanctions lists and strive to continually improve our processes to ensure that we are always in compliance with export control laws.
Antitrust Compliance
The management of Wirthwein SE is expressly committed to corporate governance that complies with antitrust law. With regard to antitrust rules of conduct for employees, we refer in this context to the "Rules of Conduct vis-à-vis Competitors" of the German Association for Materials Management, Purchasing and Logistics (BME). These rules and the applicable antitrust regulations must be observed and complied with by all employees at all times.
2. Working conditions and social standards
We respect and support the protection of universally recognized human rights and ensure that we are not complicit in human rights abuses.
Prohibition of discrimination
The international orientation and the global and sustainable growth strategy of Wirthwein SE result in a special social and cultural responsibility that arises from the cooperation with employees and business partners of different origins, religions, skin colors and world views. We therefore treat foreign cultures with respect and dignity and reject any form of discrimination. We also guarantee equal opportunities and equal treatment for all employees, regardless of gender, age, nationality, social background, religious affiliation, political and trade union activities, sexual orientation or disability. Our employees are recruited, developed and rewarded solely on the basis of their skills and qualifications.
Each of our employees is required to refrain from any form of discrimination in order to facilitate a respectful and cooperative working relationship, both within the organization and with our business partners. The ILO Conventions must be respected.
Prohibition of any form of harassment
The fundamental human right of freedom has the highest priority and is to be upheld to the highest degree at all Wirthwein locations. In this context, the personal dignity, privacy and personal rights of each individual must be particularly emphasized, protected and respected. We therefore refrain from any form of physical, sexual, psychological or verbal harassment and are committed to respectful cooperation in a spirit of partnership.
Prohibition of forced labor
Forced labor is the harshest form of forced labor and contradicts our free thinking, according to which employees can decide independently and without coercion whether they want to pursue an employment relationship within the Wirthwein Group on the basis of contractually regulated work obligations. We reject any form of forced labor and guarantee our employees fair working conditions in accordance with national standards in order to create the best possible conditions for a motivated and efficient workforce to achieve our business goals.
Prohibition of Child Labor
In order to live up to our social prudence and responsibility at all Wirthwein locations, we consider it our duty to protect children in particular from excessive demands and dangers in the context of an employment relationship.
For this reason, we reject any form of employment of children who are still in school or have not yet reached the age of 15. In addition, employees under the age of 18 must be afforded special protection from hazardous work and may only be employed at night to a limited extent, taking into account the requirements of their training. This regulation applies only if national legislation does not provide for higher age requirements.
Respect for Freedom of Association
We recognize and respect the right of our employees to freedom of assembly and association in the spirit of the free constitutional order to which we are deeply committed. The fundamental right of all employees to form and freely join trade unions must be respected. Membership of trade unions or employee representative bodies shall not be a ground for unjustified unequal treatment.
Adherence to fair working conditions
We are committed to ensuring the right to fair working conditions in accordance with applicable ILO Conventions. In particular, this includes fair compensation and benefits that meet or exceed national and local legal standards, regulations or agreements.
Fair compensation
In addition to job security, fair compensation for our employees is a top priority. The compensation we pay for work performed is at least in accordance with national legal standards and regulations. We strive to pay a living wage to ensure a decent standard of living for our employees.
Compliance with legal working time regulations
Our working hours, break and vacation policies are in line with national legal requirements to meet our social responsibility to our employees.
Encouraging personal development
We value the ongoing education and development of our employees and their willingness to take on responsibility. We encourage individual growth goals and provide opportunities for professional development, whether through training, mentoring or access to resources.
Ensuring health and safety
Protecting against workplace hazards and promoting the health of our employees are fundamental aspects of our Occupational Health and Safety policy, to which we have a special commitment to our employees.
As part of our duty of care, we provide our employees with the necessary occupational health and safety measures in accordance with national regulations to ensure a healthy working environment, job satisfaction and performance.
In addition, each employee is required to make an appropriate contribution to occupational health and safety. In particular, this means complying with the relevant regulations and behaving appropriately in the workplace in order to prevent accidents and avoid health hazards. We strive to keep the accident rate below the industry average and to continuously reduce it by setting an annual target and reviewing and evaluating it.
Protection from eviction and land confiscation
We agree not to conduct any unlawful evictions. We also agree not to unlawfully take land, forests and waters through acquisition, development or other use.
Use of Private or Public Security Forces
We believe it is our duty to refrain from hiring or using private and public security forces if there is a risk of torture and cruel, inhuman or degrading treatment, injury to life or limb, or interference with freedom of assembly or association due to a lack of company direction or control over the use of security forces.
Financial Responsibility
Our company's accountability obligations with respect to business records and accounting principles are met. We are responsible for recording, maintaining and reporting all financial activities accurately and transparently.
3. Ecological standard
Environmental and climate protection as well as the responsible use of natural resources are an integral part of our responsibility to the environment and society.
Protecting the environment
The location of our sites in ecologically valuable areas requires us to take special responsibility for nature and the environment. For this reason, we comply with national regulations and agreed standards for environmental protection. Continuous monitoring and improvement is at the heart of our business processes and is reflected in our environmental management system. As part of our manufacturing processes, we pay special attention to the resource-efficient manufacture of our products through the use of environmentally friendly, energy-efficient and innovative technologies. We continually strive to use materials with a high recycled content and to minimize CO2 emissions during production. Our goal is to make the entire life cycle of our products sustainable and to minimize environmental impact by considering all aspects of raw material selection, production and recyclability. Our energy management system sets the standard. In addition, we are committed to strict adherence to noise guidelines to protect ourselves, our employees and the environment.
We also strive to reduce all types of waste and chemicals used in the company. A responsible waste and chemical management system, which we are constantly expanding, helps us to do this.
Every employee is encouraged to contribute as much as possible to the goals of our environmental and energy policies and to continually improve them.
Protecting the climate
We integrate all energy and environmental aspects into the development process in order to minimize the use of natural resources, reduce environmental impact to the lowest possible level, and minimize greenhouse gas emissions in our value chain, thereby contributing to improved air quality. Efficient and resource-conserving production is at the forefront of these efforts. By using renewable energy, increasing energy efficiency and reducing energy consumption, we aim to reduce CO2 and other emissions.
Protecting water
The careful use of water as a resource is important to us. Withdrawal rates, water consumption and water quality are maintained and continually improved in accordance with regulatory and legal requirements.
Protecting air and soil quality
As a minimum, we are in compliance with applicable laws and regulations and local government requirements.
Handling Prohibited Substances
We observe and comply with the Minamata-Übereinkommens[4] on Mercury, the Stockholm Convention[5] on Persistent Organic Pollutants (POPs), and the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal.
Handling conflict minerals
We ensure that our products do not contain raw materials that contribute directly or indirectly to the financing and support of armed conflict and serious human rights abuses, including child and forced labor and slavery. We take appropriate measures to reduce these and require our suppliers to do the same. We also ensure due diligence to promote responsible supply chains for minerals from conflict-affected and high-risk areas in accordance with the OECD Guidelines[6].
Protecting forests
We are committed to protecting forests and to conducting our business in a way that preserves biodiversity. Responsible timber trade is a high priority for us and we ensure that we use certified timber. We also respect the rights of indigenous communities, who are often directly affected by deforestation.
Animal welfare
Animal welfare is important to us. We recognize that animals have rights and respect their dignity. All applicable international and national animal protection and welfare laws must be fully complied with. Appropriate husbandry and the concept of the "five freedoms" are fundamental and unnecessary suffering must be avoided.
Protecting Product Safety and Customer Health
The health/safety of our customers is of the utmost importance to us. We comply with all applicable product safety regulations and requirements, particularly those related to product safety and labeling and the use of hazardous substances and materials.
4. Supply chain
We hereby request our suppliers, service providers and other partners to comply with these guidelines of Wirthwein SE and its subsidiaries and to act accordingly.
The risk of using and marketing counterfeit products should also be minimized by our suppliers, service providers and other partners through the implementation of appropriate processes. In addition, a process should be implemented that ensures compliance with applicable export restrictions and economic sanctions and is transparent.
We are committed to supporting our partners in their development in the areas of sustainability, compliance, energy and the environment. This can take the form of training and interpretation of our requirements. We also provide on-site support when necessary.
5. Implementation
We have defined clear responsibilities for exercising and complying with our human rights and environmental due diligence obligations. At the highest management level, our Executive Committee members are responsible for respecting human rights and environmental protection in our operations and upstream value chain.
Adherence to the WIRTHWEIN Code of Conduct
Each manager must ensure that the Standards of Business Conduct are observed and actively supported by all employees. Each employee must comply with and act in accordance with all applicable laws and regulations and the standards of conduct set forth in this Code.
Remedial measures
Violations, especially of human rights or environmental obligations, must be stopped immediately. Actions taken will be documented and reviewed for effectiveness. If a violation is suspected, an investigation will be initiated immediately.
Consequences of violations
Employees are made aware of and trained in compliance through internal training systems. Violations of our Code of Conduct or legal requirements will inevitably have consequences.
Reporting Violations
We encourage all employees to report or ask questions about violations or suspected violations of this Code. Reporting helps us uncover misconduct and ensure the continued success and well-being of all employees and stakeholders.
Violations can be reported to managers, to the local compliance officer at the site or anonymously through the whistleblower system at wirthwein.whistleblower-system.de. Information provided by employees who report such violations will be treated confidentially and the employee will not suffer any adverse consequences.
Creglingen, im Januar 2024
[1] unglobalcompact.org/what-is-gc/mission/principles
[2] www.ilo.org
[4]http://minamataconvention.org/en
[5] www.pops.int
[6] OECD-Leitlinie: mneguidelines.oecd.org/mining.htm