1. Preamble

The Wölfel Group (Wölfel) sees itself as part of an internationally interconnected economy and is thus committed to its responsibility as a company towards society and the environment.

• Sustainability culture and commitment to sustainable development
  Wölfel promotes sustainable business practices and is committed to reducing its CO2 footprint and building responsibility for employees both within the company and throughout the value chain. Wölfel is committed to building trust throughout the value chain through transparent and sustainable practices. All suppliers are expected to agree to our Code of Conduct (CoC) as far as possible and to follow its principles and to implement measures successively where possible. Information on the current status and measures must be communicated on request. This CoC sets out the minimum requirements to promote environmental, social and economic sustainability initiatives along the supply chain. We expect our suppliers to also hold their subcontractors and partners accountable for complying with the same standards.
• Fair competition
  Wölfel advocates free and fair competition. No anti-competitive agreements or activities that affect prices or conditions will be tolerated and it will be ensured that the company acts in accordance with applicable antitrust laws. Wölfel categorically rejects competitive advantages through unfair business practices. Compliance with these principles is expected of all suppliers.
• Management system
  Suppliers are expected to establish and maintain management systems that reflect the rules and principles of this CoC and ensure compliance with them. Risks and potential dangers or grievances are to be identified and solved in this way. An anonymous reporting portal will be available and accessible to report and process any complications. Wölfel is committed to fostering a culture of transparency, integrity, and accountability, and encourages all stakeholders to report their concerns about potential violations of company policies or laws to our whistleblowing system. For this reason, Wölfel has also set up an anonymous reporting portal. All reports are taken seriously and investigated immediately and thoroughly. Compliance with this principle is expected of all suppliers.

2. Human rights and social responsibility

Human dignity is inviolable. That is why Wölfel respects the internationally recognized human rights written down in the United Nations Universal Declaration of Human Rights.

• Working hours
  Suppliers must set working hours that comply with regional legal requirements and do not endanger the health and well-being of employees. Unpaid overtime or inappropriate on-call requirements must be avoided. Wölfel expects a clear regulation on working hours and calls for the establishment of complaint channels and regular audits.
• Adequate remuneration
  All employees must receive sufficient remuneration to meet their basic needs as well as those of their families, considering local economic and social conditions. Wölfel expects its suppliers to comply with minimum wages and fair remuneration practices.
• Prohibition of child labour
  The employment of children or minors is strictly prohibited. Suppliers must ensure that their labour practices do not involve child labour, and that age verification is carried out effectively. The prevention of poverty and the promotion of education are central values of Wölfel.
• Prohibition of forced labour
  Wölfel does not tolerate any form of forced labour along the entire value chain. Forced labour includes any work or service carried out under threat of punishment or other forms of coercion, in which workers do not have a voluntary choice or are unable to freely determine their working conditions. Suppliers must ensure that all employees perform their work voluntarily and have the right to terminate the employment relationship at any time, provided that no legal or contractual obligations are violated.
• Safe working conditions
  Suppliers must ensure safe working conditions and ensure that all employees have appropriate protection in the event of illness, accidents at work or retirement. Wölfel expects compliance with labour laws and social standards that comply with health and safety regulations. Personal protective equipment must be provided for the safe performance of the work.
• Health and safety
  The physical and mental health of employees must be promoted through proper safety practices, regular training, and a corporate culture of safety. Wölfel expects its suppliers to comply with all relevant safety standards and to offer health programs for their employees. Protecting mental health also includes fair, respectful and non-discriminatory treatment of all employees and stakeholders. Any form of threats, harassment and violence in the workplace must be prevented.
• Training and skills development
  Suppliers are required to regularly train their employees and improve their qualifications to ensure long-term work capability and productivity. The training measures are to be documented and reviewed in order to promote continuous competence development.

3. Ecological responsibility and environmental protection

The protection and preservation of the natural foundations of life affects and obliges us all. Wölfel conducts its business activities in an ecologically responsible manner and is committed to the goal of a climate-neutral future.

• Optimisation of resource use and resource management
  Wölfel's suppliers are obliged to optimise material consumption and implement efficient waste management. Suppliers are expected to take steps to use resources responsibly, minimise waste, and increase the use of sustainable materials and recycling practices. In addition, they must minimise the impact of their activities on the environment and comply with all national and international regulations on resource use. It is also expected that the disposal of waste, hazardous chemicals and other harmful substances is carried out in a safe and environmentally responsible manner in order to avoid environmental impacts such as soil and water pollution.
• Energy consumption
  Energy consumption must be monitored and documented. Economical solutions must be found to improve energy efficiency and minimise energy consumption. Sustainable energy is expected to be promoted and disseminated by suppliers, provided that it does not result in a disproportionate impact on business operations.
• Conflict minerals and rare earths
  According to the OECD, mineral resources and rare earths are often located in conflictaffected and high-risk areas, which can lead directly or indirectly to armed conflicts and serious human rights violations. Wölfel calls on its suppliers to avoid conflict minerals and to respect the protection of human rights and the environment, as well as to provide information on the origin of raw materials.

4. Ethics and integrity

• Integrity and transparency
  The Wölfel Group expects the highest ethical standards from its suppliers. Any form of corruption, bribery or unethical behaviour is strictly prohibited. Suppliers must ensure that their business activities are transparent and that they act with integrity in all business relationships.
• Whistleblower mechanism
  Suppliers should introduce mechanisms that enable employees to report grievances or ethically questionable behaviour anonymously and without fear of repressive measures. A reporting system must be available and easily accessible.
• Anti-bribery and anti-corruption policy
  Wölfel's suppliers are obliged to strictly prevent any form of bribery, corruption and unethical business practices. All suppliers have the obligation to report any violation immediately. This includes both direct and indirect bribery, whether in the form of financial benefits, gifts or other benefits aimed at influencing decisions or obtaining an unlawful advantage. Suppliers shall ensure that no illegal or unethical practices are used in the selection of subcontractors, in the awarding of contracts and in cooperation with public institutions or other business partners. This also includes compliance with all relevant national and international anticorruption laws. Suppliers shall implement transparent procedures and controls to ensure that all business activities and transactions are carried out without the influence of bribery or corruption.
• Confidentiality and data protection
  Suppliers commit themselves to meet the reasonable expectations of their client, suppliers, customers, consumers and employees with regard to the protection of private information.
  Suppliers shall comply with data protection and information security laws and government regulations when collecting, storing, processing, transmitting and disclosing personal information.
• Conflict of interest
  Corporate decisions should always be made in the interest of the company and should not be influenced by (private) interests. Therefore, conflicts of interest should be avoided to prevent potential corruption.
• Export control
  Suppliers shall comply with all sanctions, customs duties and other export controls and comply with national and international laws. Risks related to export controls are to be identified and minimized.

5. Implementation and commitment

• Responsibility along the supply chain
  Wölfel aims to only work with suppliers who also take responsibility for their business practices. Suppliers are expected to drive the implementation of the aspects of the CoC within their own supply chain as well. In doing so, they must provide truthful information on the defined principles, identify possible improvements, and formulate and document appropriate measures. In exceptional cases, audits and assessments may be carried out by Wölfel or third parties commissioned by Wölfel to verify the implementation and compliance with the CoC. Wölfel expects the suppliers to implement the principles of this CoC and ensure that compliance with them continues to be guaranteed in the future.
• Commitment
  We expect our suppliers to identify risks within supply chains and take appropriate action. In the event of a suspicion of violations, suppliers will inform us promptly and, if necessary, regularly about the identified violations and risks as well as the measures taken. If a breach of the provisions of this CoC is detected, we will notify the supplier in writing without undue delay and give it a reasonable grace period to bring its conduct into line with these rules. If a remedy is not possible in the foreseeable future, the supplier shall notify us immediately and work with us to create and implement a concept with a timetable for ending or minimizing the violation.
• Acknowledgment and agreement of the supplier
  By signing this document, the supplier undertakes to act responsibly and to adhere to the principles and requirements listed as far as possible. The supplier may exclude individual subitems with justification. The supplier undertakes to communicate the content of this CoC to employees, agents and subcontractors in a way that is understandable to them and to take all necessary precautions for the implementation of the requirements.
• Consequences of the rejection of the CoC by suppliers
  If the supplier rejects this CoC, the business relationship between Wölfel and the supplier can nevertheless be continued unchanged. However, in this case, the supplier is expected to justify the rejection of the CoC and, if available, to refer to its own CoC to which the supplier is committed. If partial aspects cannot be agreed to due to a lack of measures, the supplier shall take measures to improve them as soon as possible.