Code of Conduct

Introduction / Preamble

Witte Barskamp GmbH & Co. KG (subsequently “Witte”) is committed to ecologically and socially responsible corporate management. We expect the same conduct from all our business partners. It is also a condition for our employees that they comply with the principles of ecological, social and ethical conduct and integrate these principles into the corporate culture.
Furthermore, we constantly strive to optimise our corporate actions and our products in the interests of sustainability and ask our business partners to make a contribution in the interests of a holistic approach.

For our future cooperation the business partner and Witte agree the applicability of the following regulations as a joint code of conduct. This Agreement is deemed to form the basis for all future deliveries. The contractual partners are obliged to comply with the principles and requirements of the Code of Conduct and to endeavour to contractually oblige their subcontractors to comply with the standards and regulations detailed in this document. This Agreement comes into effect on its signature. Any breach of this Code of Conduct may provide the company with grounds and a reason to end the business relationship, including all associated agreements.

The Code of Conduct is based on national laws and regulations as well as international treaties, such as the Universal Declaration of Human Rights of the United Nations, the guidelines for the rights of children and corporate action, the United Nations Guiding Principles on Business and Human Rights, and the international labour standards of the International Labour Organization

2. Requirements for business partners

2.1 Social responsibility

2.1.1 Exclusion of forced labour

Forced labour, slave labour or any comparable labour must not be used. All labour must be voluntary and the employees must be able to end the labour or their employment at any time. In addition, there must be no unacceptable treatment of labour, such as psychological hardship, or sexual and personal harassment.

2.1.2 Prohibition of child labour

Child labour must not be used in any phase of production. Suppliers are required to comply with the recommendation from the ILO conventions on the minimum age for the employment of children. Accordingly, the age should not be lower than the age at which general compulsory education ends and in any case, must not below 15 years of age. If children are encountered at work, the supplier must document measures taken in order to provide redress and to enable the children to attend a school. The rights of young employees must be protected and special protective regulations must be complied with.

2.1.3 Fair pay

The pay for regular hours worked and for overtime must correspond with the national statutory minimum wage or the minimum standards usual for the sector, depending on which amount is higher. The pay for overtime must exceed the pay for regular hours in every case. If the pay is not enough to cover the costs for usual subsistence and to form a minimum amount of savings, the business partner is obliged to raise the pay accordingly. Employees must be granted all legally stipulated benefits. Making deductions from pay as a form of punishment is not permissible. The business partner must ensure that employees receive clear, detailed and regular written information about the composition of their pay.

2.1.4 Fair working time

Working time must comply with the applicable laws or the standards for the sector. Overtime is only permissible if it is provided on a voluntary basis and does not exceed 12 hours a week, while employees must be granted at least one day off work after six successive working days. Weekly working time must not regularly exceed 48 hours.

2.1.5 Freedom of association

The right of employees to establish organisations of their choice, to join these and to hold collective negotiations must be respected. In cases in which freedom of association and the right to collective negotiations are restricted by law, alternative possibilities for an independent and free combination of employees for the purposes of collective negotiations must be granted. Employee representatives must be protected against discrimination. They must be granted free access to the workplaces of their colleagues in order to ensure that the representatives can safeguard employee rights in a legal and peaceful manner.

2.1.6 Prohibition of discrimination

Discrimination against employees in any form is not permissible. This applies, for example, to discrimination due to gender, race, skin colour, disability, political convictions, origins, religion, age, pregnancy or sexual orientation.
The personal dignity, private sphere and personal rights of every individual must be respected.

2.1.7 Occupational heath and safety in the workplace

The business partner is responsible for providing a safe and healthy working environment. By setting up and applying appropriate occupational safety systems, the necessary precautions will be taken to avoid accidents and damage to health that could occur in connection with employment activities. In addition, employees must be informed and trained regularly in the applicable occupational health and safety standards and measures. Employees will be enabled to access drinking water in sufficient quantities as well as provided access to clean sanitary facilities.

2.1.8 Complaint mechanisms

The business partner is responsible for setting up an effective complaints mechanism at company level for individuals and communities that could be affected by negative effects.

2.1.9 Handling conflict minerals

The company must establish processes in accordance with the guiding principles of the Organisation for Economic Cooperation and Development (OECD) for the conflict minerals tin, wolfram, tantalum and gold, as well as for additional commodities, such as cobalt, in order to meet duties of care for the promotion of responsible supply chains of minerals from conflict-affected and high-risk areas and will also expect this from its suppliers. Smelting and refineries without appropriate, audited duty of care processes should be avoided.

2.2 Ecological responsibility

2.2.1 Treatment and discharge of industrial waste water

Waste water from business processes, production processes and sanitary facilities must be classified, monitored, checked and, if necessary, treated before discharge. Furthermore, measures should be taken to reduce the generation of waste water.

2.2.2 Handling air emissions

General emissions from business processes (air and noise emissions) as well as
greenhouse gas emissions must be classified, routinely monitored, checked and, if necessary, treated before release. Moreover, the business partner has the task of monitoring their emission control systems and is required to find cost-effective solutions in order to avoid all emissions.

2.2.3 Handling waste and hazardous substances

The business partner must take a systematic approach to identify, treat, reduce and responsibly dispose of or recycle solid waste. Chemicals or other materials that would endanger the environment if released must be identified and treated so that safety is guaranteed when handling, transporting, storing, using, recycling or reusing these substances, and during their disposal.

2.2.4 Reducing the consumption of commodities and natural resources

The use and consumption of resources during production and the generation of waste of all kinds, including water and energy, must be reduced or avoided. Either this must be done directly at the point of origin or through procedures and measures, for example, by changing the production and maintenance processes or by processes in the company, by the use of alternative materials, by savings, by recycling or by means of reusing materials

2.2.5 Handling energy consumption/efficiency

Energy consumption must be monitored and documented. Cost-effective solutions must be found to improve energy efficiency and minimise energy consumption.

2.3 Ethical business conduct

2.3.1 Fair competition/Conflicts of interest

The standards of fair business activity, fair advertising and fair competition must be complied with. In addition, the applicable monopolies laws that apply to dealings with competitors must be applied, in particular, those that prohibit agreements and other activities that influence prices or conditions.
Furthermore, these regulations prohibit agreements between customers and suppliers that are intended to restrict customers in their freedom to autonomously determine their prices and other conditions in the event of resale.
Moreover, all conflicts of interest that could sustainably influence the business relationship must be avoided.

2.3.2 Confidentiality/Data protection/Information security

With regard to the protection of information and data of all kinds the business partner is obliged to meet the appropriate expectations of its client, the supplier, customers, consumers and employees.
When collecting, storing, processing, transmitting and passing on information and data of all kinds the business partner must comply with laws relating to data protection and information security, official regulations and, if applicable, specific requirements from relevant professional associations and organisations (e.g. VDA).

2.3.3 Intellectual property

Rights to intellectual property must be respected; technology and know-how transfers must take place so that intellectual property rights and customer information are protected.

2.3.4 Integrity/Bribery, personal gain

All business activities must be based on the highest standards of integrity. The business partner must pursue a zero tolerance policy when prohibiting all forms of bribery, corruption, blackmail and embezzlement. Procedures to monitor and implement the relevant standards must be applied in order to guarantee compliance with anti-corruption laws.

3 Implementing the requirements

With regard to supply chains we expect our business partners to identify the risks within these as well as to take appropriate measures. If there is any suspicion of a breach, as well as to secure supply chains with raised risks, the business partner must inform Witte promptly and, if applicable, regularly, about the breaches and risks identified as well to as the measures taken.

If a breach of the regulations of this Code of Conduct is identified, Witte will notify the business partner of this within one month in writing and will set an appropriate period of grace for the partner to bring their conduct into line with these regulations. If such a breach is made culpably and the continuation of the agreement until its proper termination is unreasonable for Witte, Witte can terminate the agreement after the fruitless expiry of the deadline set, if Witte has threatened this when setting the period of grace. Any legal rights to extraordinary termination without notice as well the right to compensation remain unaffected.